Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Automotive radio classification treats integrated infotainment features as supplementary, placing complete and qualifying unassembled units under the ...
Separate corporate personality prevents directors from being personally liable for company deposits without a guarantee or independent legal undertaki...
Cross-segment derivatives manipulation: integrated order patterns can support interim restraints, while director liability requires responsibility, co...
Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.
Foreign tax credit for Australian employment income cannot be denied solely because a belated return and Form No. 67 were filed late where substantive entitlement and compliance with other required formalities are undisputed. Rule 128's timing requirement is treated as a directory procedural condition in subordinate legislation and cannot curtail substantive entitlement to foreign tax credit. The credit claim was consequently required to be accepted, and the denial was set aside.
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TaxTMI 
TaxTMI 
of 4910 
