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Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
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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