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...
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
In absence of a recorded satisfaction note by Revenue, the notice date (27.05.2022) was treated as the deemed date of search for the non-searched person, fixing the deemed year of search as F.Y. 2022-23 (A.Y. 2023-24) and thus establishing the ten-year limitation block from A.Y. 2023-24 back to A.Y. 2014-15; because A.Y. 2012-13 fell outside that block the Assessing Officer lacked jurisdiction under section 153C and the assessment framed on 03.02.2023 was time-barred and was quashed, with other grounds left open.
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