Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
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Section 172 assessment procedures are examined where a shipping assessee elected annual assessment of total income under Section 172(7), while separate vessel-wise assessments were also made under Section 172(4). The notes identify the contention that, after exercising the annual-assessment option, separate assessments for individual vessels should not proceed. They also record that a return processed under Section 143(1), resulting in a refund, had become final. The High Court found the issues arguable and granted interim protection by staying recovery under the Section 172(4) assessments pending final disposal of the writ petition.
Section 172 assessment procedures are examined where a shipping assessee elected annual assessment of total income under Section 172(7), while separate vessel-wise assessments were also made under Section 172(4). The notes identify the contention that, after exercising the annual-assessment option, separate assessments for individual vessels should not proceed. They also record that a return processed under Section 143(1), resulting in a refund, had become final. The High Court found the issues arguable and granted interim protection by staying recovery under the Section 172(4) assessments pending final disposal of the writ petition.
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