Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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No overlapping proceedings under Section 6(2)(b) were established, because the petitioner did not show that any other competent authority had already initiated action on the same subject matter. The Court held that search and seizure under Section 67, including sealing of premises when required, and provisional attachment under Section 83 were within the CGST framework. It further held that statutory remedies existed for release of seized goods and de-sealing, yet the petitioner bypassed those remedies and did not cooperate with summons or the investigation. In these circumstances, the availability of an alternative efficacious remedy barred interference under Article 226, and the writ petition was dismissed.
No overlapping proceedings under Section 6(2)(b) were established, because the petitioner did not show that any other competent authority had already initiated action on the same subject matter. The Court held that search and seizure under Section 67, including sealing of premises when required, and provisional attachment under Section 83 were within the CGST framework. It further held that statutory remedies existed for release of seized goods and de-sealing, yet the petitioner bypassed those remedies and did not cooperate with summons or the investigation. In these circumstances, the availability of an alternative efficacious remedy barred interference under Article 226, and the writ petition was dismissed.
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