The Court held that a genuine buyer cannot lose ITC merely because the seller failed to deposit tax. The key takeaway is that liability must fall on the defaulter, not the innocent purchaser.
The issue was whether exempt dividend income could be taxed by overriding Rule 8D. The ITAT held that additions beyond the Section 14A framework are invalid.
The Supreme Court ruled that payments under non-compete agreements are revenue expenditures if they protect business without creating new assets. Companies can claim such fees as ordinary business expenses under Section 37(1).
Explore the complexities of computing trading income and deductible expenses for UK income tax, including the role of GAAP, statutory provisions, and tax law adjustments.
Learn about tackling tax avoidance in the UK with the Ramsay doctrine and GAAR. Explore their implications and effectiveness in combating tax avoidance strategies.
Analyzing the Ardmore Construction Ltd v HMRC case on the UK’s “source” principle in taxation, highlighting the court’s stance on income origin for tax purposes.
Explore the evolution of harmful tax practices from the OECD’s 1998 report to the BEPS Action 5 approach, focusing on transparency, substantial activity requirements, and the eradication of harmful regimes.
The arm’s length range is an everchanging range as different transfer pricing methods yield a different range of figures which may all be workable. With regard to this, the arm’s length principle can only generate a comparison of the set of conditions that would have been approved between independent enterprises.
While it may not be perfect, the member countries of the OECD focus have a tendency that the arm’s length principle should govern the judgment of transfer pricing between associated enterprises.
Discover the significance of pricing methods in detecting related party transactions. Learn how multinational companies reduce tax liabilities through progressive pricing.
