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...
Where a taxpayer precasts concrete offsite and brings personnel and machinery to a construction site, the site exhibits sufficient permanence and use of human and technical resources to constitute a fixed establishment; consequence: registration is required in the state of the construction site. Transportation and use of precast materials at that site by the same registered person, even without separate consideration or a distinct contracting party, falls within the scope of supply (Schedule I and Section 7) because the supplier is treated as a distinct person; consequence: such movements amount to supply. Procedural queries outside Section 97(2) are rejected as inadmissible.
Where a taxpayer precasts concrete offsite and brings personnel and machinery to a construction site, the site exhibits sufficient permanence and use of human and technical resources to constitute a fixed establishment; consequence: registration is required in the state of the construction site. Transportation and use of precast materials at that site by the same registered person, even without separate consideration or a distinct contracting party, falls within the scope of supply (Schedule I and Section 7) because the supplier is treated as a distinct person; consequence: such movements amount to supply. Procedural queries outside Section 97(2) are rejected as inadmissible.
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