Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
Subscriptions from members form corpus or common fund and, under the principle of mutuality, are not taxable; interest earned on bank deposits is prima facie taxable but may be appropriated to meet bona fide payments to members. The document recognises a right of appropriation whereby the society may first apply taxable interest receipts to discharge death claims, pensions, voluntary retirement and retirement benefits for members, and only thereafter draw on subscriptions if required. The operative effect directs reassessment to allow set off of such member payments against taxable receipts when determining tax liability.
Subscriptions from members form corpus or common fund and, under the principle of mutuality, are not taxable; interest earned on bank deposits is prima facie taxable but may be appropriated to meet bona fide payments to members. The document recognises a right of appropriation whereby the society may first apply taxable interest receipts to discharge death claims, pensions, voluntary retirement and retirement benefits for members, and only thereafter draw on subscriptions if required. The operative effect directs reassessment to allow set off of such member payments against taxable receipts when determining tax liability.
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