Business support recruitment and training receipts qualify for presumptive business taxation, not professional taxation under technical consultancy ru...
Treaty exemption for foreign permanent-establishment management fees prevailed, while dividend expense disallowance remained limited to an accepted al...
Centralised assessment transfers: participation after requesting centralisation can bar technical jurisdictional challenges, while assessment disputes...
Binding precedent remains operative despite pending challenge, supporting deletion of interest disallowance when debt is converted into preference sha...
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
Consent terms filed jointly in oppression and mismanagement proceedings were incorporated into the appellate disposition, making the settlement binding on the parties' inter se rights, liabilities and conduct. The appeal challenging findings that amendments to the articles of association and a rights issue were oppressive was allowed by consent, and those portions of the impugned order were quashed. No independent adjudication of the challenged merits occurred.
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