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...
Turnover mismatches under percentage-completion accounting cannot alone establish suppressed income where customer advances remain recorded as liabili...
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Section 110(5) of the Customs Act limits provisional attachment of a bank account to six months, with only one further extension of up to six months based on written reasons communicated before the original period expires. A show-cause notice or pending adjudication cannot independently prolong attachment beyond that statutory maximum. Once the period ends, the attachment ceases by efflux of time and cannot be continued through administrative action. Continued freezing without statutory authority requires defreezing of the account, without limiting any other action permitted by law.
Section 110(5) of the Customs Act limits provisional attachment of a bank account to six months, with only one further extension of up to six months based on written reasons communicated before the original period expires. A show-cause notice or pending adjudication cannot independently prolong attachment beyond that statutory maximum. Once the period ends, the attachment ceases by efflux of time and cannot be continued through administrative action. Continued freezing without statutory authority requires defreezing of the account, without limiting any other action permitted by law.
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