Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Personal-use motor cars constitute personal effects rather than capital assets where their intimate and common personal use is established. Non-claim of depreciation, disallowance of car expenses as personal, and absence of business activity support that classification; balance-sheet treatment as a fixed asset does not prevail over actual user. Accordingly, transfer of such a motor car does not generate an allowable capital loss. Authorities concerning business assets or depreciation were distinguishable.
Personal-use motor cars constitute personal effects rather than capital assets where their intimate and common personal use is established. Non-claim of depreciation, disallowance of car expenses as personal, and absence of business activity support that classification; balance-sheet treatment as a fixed asset does not prevail over actual user. Accordingly, transfer of such a motor car does not generate an allowable capital loss. Authorities concerning business assets or depreciation were distinguishable.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
