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...
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Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
Explanation 4 to section 28 preserved the pre-amendment customs recovery regime for notices issued before 29-03-2018, so the later supplementary-notice mechanism under section 28(7A) and the 2019 Regulations could not be applied to a 2014 show cause notice. A corrigendum adding fresh allegations and evidence after completion of the final hearing could not be treated as a valid supplement to the notice and had to be ignored at final adjudication. The writ petition was allowed, and the final order was directed to be passed on the original notice without considering the corrigendum.
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