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...
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
Dividend remittance to foreign shareholders was permitted despite pending tax demands because those demands were already under challenge and stayed, and the Court found that an indefinite embargo on repatriation was unjustified. Revenue protection was maintained by requiring the company to furnish an auto-renewable interest-bearing FDR of equivalent value, comply with remittance rules, and deduct tax at source; the earlier lien on existing FDRs was lifted. Separately, refund for AY 2021-22 was allowed to be adjusted against the demand for AY 2018-19 on the petitioner's concession, and the Department was protected from any contempt allegation if the refund was adjusted against outstanding demand for AY 2020-21.
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