Pure reimbursement without income element escapes tax withholding, while delayed withholding and unsupported provisions face deferred or renewed scrut...
Public benefit requirement defeats charitable registration where residents' association services are reciprocal, member-only facilities governed by mu...
Exempt-income expenditure disallowance is confined to investments that actually generated exempt income, while supported business expenses remain dedu...
Objective characteristics and principal use govern mining-tyre classification, while fresh advance ruling applications may rely on additional technica...
Reopening of assessment was upheld where the recorded reasons showed fresh tangible material from impounded documents and a director's statement, and the assessee had not fully disclosed the crucial Clause 7 entitlement to 35% of gross sale receipts; no earlier opinion on the receipt's true character had been formed, so change of opinion did not apply. The Court also held that reopening must stand or fall on the recorded reasons alone. On the merits, the assessee's 35% entitlement under the AOP agreement was not a share of profit, because it arose from gross receipts before project expenses and was diverted by overriding title; it was therefore taxable as business income.
Reopening of assessment was upheld where the recorded reasons showed fresh tangible material from impounded documents and a director's statement, and the assessee had not fully disclosed the crucial Clause 7 entitlement to 35% of gross sale receipts; no earlier opinion on the receipt's true character had been formed, so change of opinion did not apply. The Court also held that reopening must stand or fall on the recorded reasons alone. On the merits, the assessee's 35% entitlement under the AOP agreement was not a share of profit, because it arose from gross receipts before project expenses and was diverted by overriding title; it was therefore taxable as business income.
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