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...
The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
The article addresses limitation for passing reassessment orders, holding that a judicial remand prescribing procedural timelines (supply of reasons, opportunity to file and dispose objections, and a brief bar before assessment) does not qualify as a "finding" or "direction" that triggers the extended limitation available where reassessment is made "in consequence of or to give effect to" a court finding or direction. Consequently, extended limitation is not attracted and ordinary limitation rules apply; after computing excluded periods from earlier writ proceedings and the additional statutory extension, the last date to pass reassessment had expired, rendering reassessment time barred and the writ allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4816 
Join Channel 
