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...
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
Cessation of liability under tax law was not attracted where long-standing foreign trade creditors remained recorded as liabilities and were not written off in the year under review; alleged waivers were reflected and offered to tax only in a later year. The legal principle applied required a cessation of liability in the year and a corresponding benefit to the taxpayer in cash, kind or otherwise; absent evidence that liabilities ceased or that the taxpayer became richer by remission during the year, the prior addition under the cessation rule was deleted.
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