Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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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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