Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Ratification of resignation acceptance validates separation retrospectively, while withdrawal may be refused through reasoned administrative discretio...
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Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.
Actuarial-deficit contributions to an approved superannuation fund are distinguished from ordinary annual and initial contributions by their purpose. Ad hoc payments required to align fund assets with actuarial liabilities and cure accumulated funding deficiencies fall outside the Rule 87 ceiling for ordinary annual contributions; applying that ceiling could undermine the fund's solvency and the deduction framework for approved funds. A reasoned appellate determination based on jurisdictional precedent is not perverse or arbitrary merely because the revenue disputes its application. The disallowance of actuarially determined deficit contributions was deleted, and the revenue's challenge failed.
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