Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Income of a public charitable trust with objects of general public utility and no entitlement of members or trustees to any share in the income is not to be taxed at the maximum marginal rate merely because the trust is unregistered under sections 12AA/12AB and does not claim exemption under sections 11 to 13. The note states that the rule in section 164 applies to income receivable for beneficiaries with indeterminate or unknown shares and cannot be mechanically extended to every public charitable trust. Taxation should instead be at the normal rates applicable to an association of persons where no beneficiary share exists.
Income of a public charitable trust with objects of general public utility and no entitlement of members or trustees to any share in the income is not to be taxed at the maximum marginal rate merely because the trust is unregistered under sections 12AA/12AB and does not claim exemption under sections 11 to 13. The note states that the rule in section 164 applies to income receivable for beneficiaries with indeterminate or unknown shares and cannot be mechanically extended to every public charitable trust. Taxation should instead be at the normal rates applicable to an association of persons where no beneficiary share exists.
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