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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
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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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