Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
International transaction characterisation of domestic divestment of support services business rejected; transaction between resident associated enter...
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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