Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
The two appellate authorities have concurrently failed to appreciate not only the fact that the Assessee was entitled to file the 'C' declaration forms even at the appellate stage, which was nothing but continuation of the assessment proceedings, but also, they being the fact finding authority, were entitled to peruse the facts as the assessment authority- HC
The two appellate authorities have concurrently failed to appreciate not only the fact that the Assessee was entitled to file the 'C' declaration forms even at the appellate stage, which was nothing but continuation of the assessment proceedings, but also, they being the fact finding authority, were entitled to peruse the facts as the assessment authority- HC
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