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...
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
Computation of limitation for reopening after a search must treat the six-year block and the ten-year outer limit differently: the six-year period is computed with reference to the assessment year relevant to the previous year in which the search occurred, while the ten-year outer limit is reckoned backwards from the end of that assessment year. Applying this method to a search on 04.03.2022 places AY 2013-14 as the tenth year and excludes AY 2012-13; consequently a notice issued under the reopening provision for AY 2012-13 was held time-barred and quashed.
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