Embezzlement losses in charitable institutions remain allowable when misappropriation is established, irrecoverable, and not a specified-person benefi...
National long-distance undertaking status supports deduction where separately licensed infrastructure, resources, revenue, and expenditure establish c...
Agency reimbursement income follows contractual deposit-liability computation, while pending deposit collections do not constitute deemed-dividend loa...
Membership-consent thresholds for oppression petitions are satisfied by unchallenged voter-list consents, while unsupported forgery claims require pro...
Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise.
Transfer-pricing tolerance under Rule 10CA(7) can apply where an internal comparable produces a single value, since its arithmetical mean remains that value. Where the variation falls within the notified tolerance, the declared price is treated as arm's length. Corporate-guarantee commission may be determined at 0.5% where identical facts and unchanged circumstances support reliance on an earlier determination. Notional interest on outstanding associated-enterprise receivables depends on verifying a uniform policy of not charging interest to third-party export customers; if substantiated by evidence, no interest adjustment should arise.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
