Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Integrated golf function determines classification, placing launch monitors and simulators under other golf equipment rather than measuring instrument...
Public servant status under anti-corruption law extends to recognised stock exchange leadership; constitutional and sanction challenges do not succeed...
Acquiescence, homebuyer protection and clean-slate resolution principles prevent landowners from disrupting an integrated project through late termina...
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Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
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