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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Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
Writ jurisdiction remains available despite an alternate statutory remedy where the challenge concerns seizure power, jurisdictional facts or deficient administrative decision-making, although factual merits remain for the statutory authority. Foreign-exchange seizure powers cannot retrospectively reach completed pre-commencement transactions, but may extend to actual payments made after commencement under a continuing arrangement. Connected financial transactions may be examined as a whole to establish a preliminary reason to believe, and recorded reasons cannot later be replaced by new grounds. Regulatory and tax proceedings do not preclude an independent foreign-exchange inquiry. Refusal of an overseas-investment no-objection certificate requires disclosed, rational reasons linked to the investigation; the unreasoned refusal required fresh consideration.
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