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...
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
Denial of opportunity to test third-party evidence by cross-examination breaches natural justice and, where additions rest solely on uncorroborated seized material and a general statement not specifically identifying the taxpayer, such material cannot discharge the Revenue's onus to prove undisclosed consideration; accordingly the addition was unsustainable and deleted. The analysis emphasises that reliance on third-party search material requires both specific linkage to the taxpayer and procedural fairness through disclosure and the right to confront the witness; absent corroboration, the material only raises suspicion and does not justify tax additions.
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