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...
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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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