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...
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
Validity of a notice under section 143(2) was contested on limitation and service grounds: the revised/rectified return filed later was held to relate back to the original return date, so the six month limitation for issuing a notice ran from the original filing and expired before the notice dated 22.09.2019; additionally no notice was served within the statutory period due to change of address/name/email, and because service of the section 143(2) notice is mandatory, the assessment was held void and quashed.
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