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Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
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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...
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Reassessment of a partner cannot rest on notional interest on capital or remuneration where the partnership deed merely enables, rather than mandates, those payments. Clauses subject to mutual agreement, including a subsequent amendment providing that no interest was payable, did not establish an enforceable entitlement or actual receipt by the partner. Without material showing that the partner received interest or remuneration, there was no basis to infer income escaping assessment. The High Court therefore quashed the reassessment notices issued to the partner.
Reassessment of a partner cannot rest on notional interest on capital or remuneration where the partnership deed merely enables, rather than mandates, those payments. Clauses subject to mutual agreement, including a subsequent amendment providing that no interest was payable, did not establish an enforceable entitlement or actual receipt by the partner. Without material showing that the partner received interest or remuneration, there was no basis to infer income escaping assessment. The High Court therefore quashed the reassessment notices issued to the partner.
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