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...
Continuing offence of money-laundering: discharge set aside and proceedings reinstated where laundering continued after inclusion of predicate offence...
An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
An application under Section 119(2)(b) challenged refusal to permit filing a revised return beyond five years; the High Court found the taxpayer had pursued rectification within the five year window and had reasonably relied on rectification as the remedy. The court held the authority could not ignore the circular's temporal condition, treated the misdeclaration as a bona fide error without deciding revised return merits, set aside the impugned order and remitted the matter for fresh consideration of the revised return for the relevant assessment year in accordance with law.
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