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...
Reopening assessments by issuing a notice for reassessment beyond three years is invalid where the statutory conditions for extended reassessment and required sanction/approval were not satisfied; such notices are void ab initio and the consequent assessment orders are liable to be quashed. Where initial reassessment proceedings were dropped, issuing a fresh reassessment notice without first following the mandated pre-reopening consultation and disposal procedure is contrary to the reassessment scheme and therefore invalid; a second notice issued on the same recorded reasons without complying with that procedure is quashed along with resulting assessment orders.
Reopening assessments by issuing a notice for reassessment beyond three years is invalid where the statutory conditions for extended reassessment and required sanction/approval were not satisfied; such notices are void ab initio and the consequent assessment orders are liable to be quashed. Where initial reassessment proceedings were dropped, issuing a fresh reassessment notice without first following the mandated pre-reopening consultation and disposal procedure is contrary to the reassessment scheme and therefore invalid; a second notice issued on the same recorded reasons without complying with that procedure is quashed along with resulting assessment orders.
Note: It is a system-generated summary and is for quick reference only.
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