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...
Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
Rectification of an assessment order extinguished the earlier addition made for share premium, merging the rectified order with the original assessment and preventing appellate re-adjudication; consequently the deletion effected by the assessing officer under rectification stands effective. Separately, where share subscribers were non-residents and no evidence supported domestic place of effective management, the valuation provision for share premium did not apply to shares issued to non-resident subscribers, so the addition was unsustainable on merits and deleted.
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