Capital-gains exemption for charitable trusts extends to qualifying fixed deposits, while unrecoverable TDS write-offs may constitute income applicati...
India-UK treaty characterisation of telecom-service receipts as business profits withstands unilateral domestic-law amendments for Indian tax purposes...
Transfer-pricing reimbursement adjustments require uncontrolled comparables and cannot become expense-genuineness reviews, resulting in deletion of th...
Annulment of a securities trade ends the transaction and makes subsequent physical delivery of the shares purposeless where the shares have been returned to the selling member. The purchaser is entitled to recover the purchase consideration with interest from the Exchange, rather than pursue trading-loss damages. The selling member is not a necessary party because the settlement mechanism creates no direct buyer-seller contract requiring relief against that member after annulment; arbitration and closing-out remedies are therefore inapplicable. An indemnity limited to dispute-resolution references does not grant the Exchange general immunity, and Clearing House non-liability provisions concerning title or validity of securities do not bar refund liability arising from annulment.
Annulment of a securities trade ends the transaction and makes subsequent physical delivery of the shares purposeless where the shares have been returned to the selling member. The purchaser is entitled to recover the purchase consideration with interest from the Exchange, rather than pursue trading-loss damages. The selling member is not a necessary party because the settlement mechanism creates no direct buyer-seller contract requiring relief against that member after annulment; arbitration and closing-out remedies are therefore inapplicable. An indemnity limited to dispute-resolution references does not grant the Exchange general immunity, and Clearing House non-liability provisions concerning title or validity of securities do not bar refund liability arising from annulment.
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TaxTMI 
TaxTMI 
of 4888 
