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...
Admissibility of a belated exercise of the option for the concessional tax regime under section 115BAA turned on procedural compliance versus substantive intention: Tribunal held that filing Form No.10IC prior to processing together with a defect-corrected/revised return demonstrated clear intention to opt for 115BAA, relied on coordinate-bench precedents favouring substance over minor procedural lapses, distinguished contrary authority on its facts, allowed the appeal and directed the Assessing Officer to verify Form No.10IC and grant the concessional regime if the form was in order.
Admissibility of a belated exercise of the option for the concessional tax regime under section 115BAA turned on procedural compliance versus substantive intention: Tribunal held that filing Form No.10IC prior to processing together with a defect-corrected/revised return demonstrated clear intention to opt for 115BAA, relied on coordinate-bench precedents favouring substance over minor procedural lapses, distinguished contrary authority on its facts, allowed the appeal and directed the Assessing Officer to verify Form No.10IC and grant the concessional regime if the form was in order.
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