Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Demutualisation share transfers are to be taxed as long-term capital gains when the holding period and cost are determined by reference to pre-demutualisation membership; the statutory demutualisation cost rule requires adopting the original membership acquisition cost or its written down value as cost of acquisition, notwithstanding prior depreciation claimed on the membership card. The assessing officer's reliance on general short-term provisions is displaced by the specific demutualisation mechanism and binding precedent, leading to acceptance of original membership cost and long-term treatment of the gain.
Demutualisation share transfers are to be taxed as long-term capital gains when the holding period and cost are determined by reference to pre-demutualisation membership; the statutory demutualisation cost rule requires adopting the original membership acquisition cost or its written down value as cost of acquisition, notwithstanding prior depreciation claimed on the membership card. The assessing officer's reliance on general short-term provisions is displaced by the specific demutualisation mechanism and binding precedent, leading to acceptance of original membership cost and long-term treatment of the gain.
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