Benami transaction and beneficial ownership: documentary and circumstantial evidence show payors were true beneficiaries, resulting in PBPTA consequen...
Denial of Preferential Treatment under SAFTA overturned where unchallenged Country of Origin certificate warranted exemption under Notification benefi...
Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue's challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee's conduct, rendering the assessments invalid and sustaining the Tribunal's view against the Revenue. - HC
Reassessment notices under Section 148 for AYs 2002-03 and 2005-06 were held time-barred as they were issued beyond two years from the end of the relevant assessment years; accordingly, the Revenue's challenge failed on limitation. For AYs 2006-07 and 2007-08, treating the assessee as a representative assessee/agent without issuing notice and passing an order under Section 163(2) was held to be non-compliance with a mandatory statutory condition; the breach could not be cured by relying on the assessee's conduct, rendering the assessments invalid and sustaining the Tribunal's view against the Revenue. - HC
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