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    Retrospective input tax credit relief removes delayed-availment demand, while mismatch claims and consequential penalty require fresh adjudication
    Section 13(1)(b) belongs at assessment, not registration; provisional registration cancellation powers cannot exceed section 12AB's scope
    Section 80-IA eligibility, change of opinion, and audit-driven reopening lead to invalid reassessment proceedings
    Electronic dispatch determines reassessment notice issuance, requiring Section 148A safeguards when delivery occurs after the statutory transition.
    Section 263 revision requires demonstrated error and Revenue prejudice; completed inquiry cannot be reopened merely for deeper verification
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      Section 149 permits amendment of a bill of entry where...

      Bill of entry amendment remains available where loss evidence predates final clearance for home consumption after provisional assessment.

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      CustomsJuly 23, 2026Case LawsHC
      Section 149 permits amendment of a bill of entry where supporting documentary evidence existed when goods were cleared for home consumption. The notes distinguish removal of imported goods under provisional assessment from clearance for home consumption, stating that removal does not constitute clearance until final assessment. As the police report recording the cargo loss was available before final assessment, the statutory condition for amendment was met. Amendment of the bill of entry for Di-Ammonium Phosphate lost during discharge was therefore permissible, and the consequential refund was sustained.

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      ActsIncome Tax