Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Prolonged pre-trial incarceration in money-laundering proceedings, assessed alongside the Article 21 right to a speedy trial, supported regular bail where a voluminous charge-sheet and extensive witness list made early commencement and conclusion of trial unlikely. Parity with a co-accused already released on bail further supported release. Regular bail was made subject to stringent conditions addressing attendance at trial, non-interference with evidence or witnesses, travel restrictions, and deposit of passports to mitigate risks of absconding or re-offending.
Prolonged pre-trial incarceration in money-laundering proceedings, assessed alongside the Article 21 right to a speedy trial, supported regular bail where a voluminous charge-sheet and extensive witness list made early commencement and conclusion of trial unlikely. Parity with a co-accused already released on bail further supported release. Regular bail was made subject to stringent conditions addressing attendance at trial, non-interference with evidence or witnesses, travel restrictions, and deposit of passports to mitigate risks of absconding or re-offending.
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