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...
Cross-segment derivatives trading was treated prima facie as manipulative where connected companies moved futures prices through aggressive orders while holding larger, sentimentally opposite options positions and pre-positioned options orders. Artificial futures-price movements enabled favourable options execution, while cancelled, inexecutable futures orders added deceptive order-book depth. Repeated deliberate futures losses coupled with greater options gains were considered inconsistent with legitimate hedging, arbitrage, speculation, or rational profit-maximising conduct. Company directors responsible for business conduct faced a rebuttable presumption of vicarious liability and joint-and-several impounding of gains attributable to their companies. Interim directions restricted market access, preserved assets and gains, and required asset disclosures pending investigation.
Cross-segment derivatives trading was treated prima facie as manipulative where connected companies moved futures prices through aggressive orders while holding larger, sentimentally opposite options positions and pre-positioned options orders. Artificial futures-price movements enabled favourable options execution, while cancelled, inexecutable futures orders added deceptive order-book depth. Repeated deliberate futures losses coupled with greater options gains were considered inconsistent with legitimate hedging, arbitrage, speculation, or rational profit-maximising conduct. Company directors responsible for business conduct faced a rebuttable presumption of vicarious liability and joint-and-several impounding of gains attributable to their companies. Interim directions restricted market access, preserved assets and gains, and required asset disclosures pending investigation.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
