Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
Modified returns after business reorganisation must be assessed within pending proceedings, barring parallel scrutiny and consequential transfer prici...
Article 226 writ jurisdiction does not ordinarily permit a party to bypass an efficacious customs appellate remedy or its statutory limitation period. Allegations of coercion, waiver of written notice or personal hearing, service of the adjudication order, and procedural non-compliance may require factual determination in the statutory appeal unless they establish a patent jurisdictional defect or clear denial of natural justice. Substantial delay in invoking writ jurisdiction further weighs against intervention. A delayed customs writ was dismissed, with confiscation, penalty, and the evidentiary effect of relevant documents left open for determination by the competent appellate forum.
Article 226 writ jurisdiction does not ordinarily permit a party to bypass an efficacious customs appellate remedy or its statutory limitation period. Allegations of coercion, waiver of written notice or personal hearing, service of the adjudication order, and procedural non-compliance may require factual determination in the statutory appeal unless they establish a patent jurisdictional defect or clear denial of natural justice. Substantial delay in invoking writ jurisdiction further weighs against intervention. A delayed customs writ was dismissed, with confiscation, penalty, and the evidentiary effect of relevant documents left open for determination by the competent appellate forum.
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TaxTMI 
TaxTMI 
of 4894 
