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...
Protective assessment cannot co-exist where substantive additions on the same income are sustained in the hands of the correct assessee; the tribunal found the assessing officer had identified and made substantive additions in the partners' hands which were affirmed on appeal, and therefore the protective addition against the partnership firm must be deleted because permitting both would tax the same income twice. The protective assessment is a temporary revenue-protection measure and loses relevance once the real assessee is determined and income is substantively assessed in that persons hands. The appeal was allowed and the protective addition deleted.
Protective assessment cannot co-exist where substantive additions on the same income are sustained in the hands of the correct assessee; the tribunal found the assessing officer had identified and made substantive additions in the partners' hands which were affirmed on appeal, and therefore the protective addition against the partnership firm must be deleted because permitting both would tax the same income twice. The protective assessment is a temporary revenue-protection measure and loses relevance once the real assessee is determined and income is substantively assessed in that persons hands. The appeal was allowed and the protective addition deleted.
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