Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period.
Reopening after four years requires fresh tangible material and satisfaction of the proviso to section 147; a reassessment cannot rest on a mere change of opinion. Audit objections led the Assessing Officer to re-examine balance-sheet documents and records already available during the original assessment, without new evidence or information indicating escaped income. The Tribunal quashed the reassessment for lack of jurisdiction. High Court found no substantial question of law, affirming that the Assessing Officer could not reopen the assessment solely through reappraisal of existing material beyond the four-year period.
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