INCOME TAX – transfer pricing – whether consideration exceeded arm's length consideration – consideration that might have been reasonably expected between independent parties dealing at arm’s length – meaning of property – meaning of consideration – what constitutes arm’s length consideration for acquisition of property
INCOME TAX – whether determinations excessive – whether decision by delegate without authority makes assessment excessive
CONSTITUTIONAL LAW – retrospective effect of taxation legislation – whether retrospectivity results in arbitrary and incontestable tax. Click here