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...
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
Interplay between limitation under section 144C(13) and section 153 was examined, with the tribunal considering the Madras High Court view that the two provisions are inter dependent and overlapping for matters under section 92CA; the tribunal concluded the timeline for passing final assessment orders must be determined with reference to section 144C read with section 153 and found the final assessment orders in five assessment years were passed beyond that limitation period. Outcome: the impugned final assessment orders were quashed as time barred.
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