Spreadover of income permitted where evidence shows earlier earning, subject to administrative discretion and time limits. Spreadover of income may be permitted when evidence shows assets represent income of earlier years; Sections 68-69B are enabling and do not preclude allocation to prior years. Spreadover must not be used to shift income to years before business commencement, after peak credit, or into loss years without reasonable basis. The Commissioner of Income Tax may grant spreadover where circumstantial evidence (large sales, licences, quotas, etc.) indicates multi year earning, subject to a conventional duration limit and higher approval if that limit is to be exceeded.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Spreadover of income permitted where evidence shows earlier earning, subject to administrative discretion and time limits.
Spreadover of income may be permitted when evidence shows assets represent income of earlier years; Sections 68-69B are enabling and do not preclude allocation to prior years. Spreadover must not be used to shift income to years before business commencement, after peak credit, or into loss years without reasonable basis. The Commissioner of Income Tax may grant spreadover where circumstantial evidence (large sales, licences, quotas, etc.) indicates multi year earning, subject to a conventional duration limit and higher approval if that limit is to be exceeded.
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