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...
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
Limitation for passing a final assessment under section 144C(13) must be assessed in light of the interplay between section 144C and section 153: the tribunal applied preceding decisions holding the two provisions to be mutually inclusive and overlapping, so the limitation period for a 144C(13) assessment is to be governed with reference to section 153 read with section 144C. Applying that principle, the impugned final assessment under section 143(3) read with 144C(13) was held timebarred and quashed. Parties are granted liberty to revive the appeal on merits if the pending Supreme Court larger bench decision requires modification.
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