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...
Beneficial ownership was sufficient to sustain proceedings under sections 241-242 and 59 where the transferee had paid full consideration, the sale was confirmed in foreign liquidation, and the liquidator had acknowledged that legal and financial interest in the shares had vested in it; the company could not rely on its own failure to complete transfer formalities to deny locus. The EOGM notice was held valid because it was sent to the liquidator's official email address and there was no legal requirement to send it separately to the secretary. Share transfer under the articles was also held to carry the transferor's obligations, including the non-compete covenant, and the transferee was directed to be admitted as shareholder subject to that covenant.
Beneficial ownership was sufficient to sustain proceedings under sections 241-242 and 59 where the transferee had paid full consideration, the sale was confirmed in foreign liquidation, and the liquidator had acknowledged that legal and financial interest in the shares had vested in it; the company could not rely on its own failure to complete transfer formalities to deny locus. The EOGM notice was held valid because it was sent to the liquidator's official email address and there was no legal requirement to send it separately to the secretary. Share transfer under the articles was also held to carry the transferor's obligations, including the non-compete covenant, and the transferee was directed to be admitted as shareholder subject to that covenant.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4807
Join Channel
TaxTMI 
