Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
Turnover is a relevant comparability factor in transfer pricing because scale affects profitability, risk and economies of scale; disproportionately large software companies were therefore excluded, while judicial discipline and the doctrine of merger required following the jurisdictional High Court view. Companies lacking reliable segmental data, showing mixed product and service activities, or failing employee cost and service revenue filters were treated as unsuitable comparables. By the same functional test, a software services company with support from its annual report was included. In the marketing support segment, an indenting and trading entity was excluded, while an advertising agency was included because advertising and marketing support operate in the same promotional domain.
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