Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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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