Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
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ITAT adjudicated that a family trust established through a will is not subject to Minimum Alternate Rate (MAR) taxation. The Tribunal held that under Section 164(1) First Proviso, such trusts qualify as Association of Persons (AOP) and should be taxed at standard AOP rates. The Central Processing Center's (CPC) application of MAR was deemed legally incorrect. CBDT Circular No.557 further clarified that family trusts created by will are exempt from MAR, with the specific proviso overriding general taxation provisions. The Tribunal consequently ruled in favor of the assessee, mandating taxation at normal AOP rates instead of MAR.
ITAT adjudicated that a family trust established through a will is not subject to Minimum Alternate Rate (MAR) taxation. The Tribunal held that under Section 164(1) First Proviso, such trusts qualify as Association of Persons (AOP) and should be taxed at standard AOP rates. The Central Processing Center's (CPC) application of MAR was deemed legally incorrect. CBDT Circular No.557 further clarified that family trusts created by will are exempt from MAR, with the specific proviso overriding general taxation provisions. The Tribunal consequently ruled in favor of the assessee, mandating taxation at normal AOP rates instead of MAR.
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