The dispute concerns whether penal show-cause notices for clandestine removal of goods can be based on investigative material collected by officers of a different commissionerate when the taxpayer maintains an additional registered place of business there; shared evidence, recorded statements, and corroborative material may lawfully support issuance of the notice, and procedural challenge at the pre-adjudication stage may be premature given the availability of reply and personal hearing remedies. (AI Summary)
TaxTMI