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...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Interactive touchscreen panels with integrated computing functions fall under automatic data-processing machines rather than display monitors for cust...
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Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
Change of opinion precludes reassessment of share-capital and investment transactions already examined through detailed scrutiny, where the assessee neither concealed nor withheld material; an anonymous complaint alone cannot reopen those matters. Reassessment notices converted into show-cause notices under the amended regime must be issued within the surviving limitation period after excluding the stay period and response time. Extended limitation cannot apply unless the statutory conditions are invoked and recorded, and sanction is obtained from the competent authority where the relevant period has elapsed. A notice issued beyond the surviving period is void, rendering consequential reassessment, demand and penalty actions unsustainable, subject to fresh proceedings where legally permissible.
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