Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
Actuarial deficit contributions to an approved superannuation fund are characterised by their purpose. Contributions made to bridge actuarially determined deficits, including prior-year deficiencies, are ad hoc gap-filling payments rather than ordinary annual contributions subject to the Rule 87 ceiling or initial contributions. Recurrence of deficits does not alter that character. Applying the ceiling to contributions necessary to meet actuarial liabilities could impair the fund's solvency and conflict with the deduction scheme for approved superannuation funds. On that basis, disallowance of the actuarial deficit contributions was deleted and the revenue's appeal failed.
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