Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
A writ petition against a customs show cause notice based on a tariff classification dispute was declined because the controversy required adjudication by the statutory authority, and the recognised exception for interference at the notice stage, such as absence of jurisdiction or abuse of process, was not made out. The petitioner was left to reply to the notice and pursue the statutory process. A separate natural justice challenge based on absence of a pre-consultation hearing was not entertained in writ jurisdiction because there was no specific pleading, and that contention was left open for consideration by the adjudicating authority.
A writ petition against a customs show cause notice based on a tariff classification dispute was declined because the controversy required adjudication by the statutory authority, and the recognised exception for interference at the notice stage, such as absence of jurisdiction or abuse of process, was not made out. The petitioner was left to reply to the notice and pursue the statutory process. A separate natural justice challenge based on absence of a pre-consultation hearing was not entertained in writ jurisdiction because there was no specific pleading, and that contention was left open for consideration by the adjudicating authority.
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