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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A sole testamentary family trust created under a deceased's will is discussed as falling within proviso (ii) to section 164(1). The note states that its assessment as an association of persons does not by itself attract taxation at the maximum marginal rate under section 167B, because the statutory proviso applies to a trust that is the only trust declared by will. It also refers to a CBDT clarification and a prior Tribunal decision as supporting taxation otherwise than at the maximum marginal rate. The stated conclusion is that income of the sole testamentary trust is not taxable at that rate for the relevant assessment years.
A sole testamentary family trust created under a deceased's will is discussed as falling within proviso (ii) to section 164(1). The note states that its assessment as an association of persons does not by itself attract taxation at the maximum marginal rate under section 167B, because the statutory proviso applies to a trust that is the only trust declared by will. It also refers to a CBDT clarification and a prior Tribunal decision as supporting taxation otherwise than at the maximum marginal rate. The stated conclusion is that income of the sole testamentary trust is not taxable at that rate for the relevant assessment years.
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