Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
In writ proceedings, a taxpayer who received a show cause notice alleging wilful suppression and invoking Section 74, but filed no reply, made payment without protest, and accepted before the adjudicating authority that tax, interest and penalty would be paid, was held estopped from taking a contrary stand later. The Court treated the recorded admission and unchallenged adjudication note as decisive, and held that prior voluntary payment after audit detection did not by itself defeat Section 74 where the allegation of suppression remained uncontested. On that basis, no interference under Article 226 was made and the writ challenge failed.
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