Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
Extended limitation for sale of attached immovable property operates retrospectively as a procedural amendment only where the original limitation had not expired when the amendment took effect; it cannot revive already time-barred recovery claims. The seven-year period therefore applied to later assessment years whose unamended limitation remained alive, while sale proceedings for earlier time-barred years were barred. Tax Recovery Officer functions concerning attachment, sale proclamation and setting aside sales are quasi-judicial, allowing exclusion of the Supreme Court-prescribed COVID-19 limitation period and court-ordered stay periods. Where no appeal is filed, limitation under Rule 68B begins after expiry of the notice-of-demand period, when the assessment becomes final for recovery purposes.
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