Finality of tax liability was central to the closure of criminal...

Finality of tax liability was central to the closure of criminal prosecution. The liability dispute had not become final when the Trial Court closed the prosecution; the tax demand was determined, accepted and complied with only afterwards. Closure on the premise that the liability had already been fully satisfied therefore failed to account for material subsequent developments. The closure order was set aside, and the matter was remanded to the Trial Court for fresh consideration in accordance with law, without any view on the merits of the criminal prosecution.