Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
Loan advanced in the ordinary course of business may generate an allowable revenue loss when waived under a settlement, provided it formed part of the taxpayer's commercial activities and neither acquired a capital asset nor represented a long-term capital investment. Financial participation through a shareholder-financier arrangement, repayable from business surplus, can retain its business character. The waiver was treated as incidental to business, distinguishable from an advance made to acquire immovable property, and the deduction was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4907 
