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...
An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
An inchoate agreement to sell, lacking execution by both parties and showing patent ambiguity, could not be treated as conclusive evidence of receipt of unaccounted on-money. The Tribunal held that an admission must be clear, unambiguous and unconditional, and that the seized document, without material particulars such as witness details or the drafter's identity and without the beneficiary's participation, did not justify an inference of undisclosed cash receipts. The additions based on that document were therefore deleted, and the consequential penalty was also deleted.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
