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...
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Validity of reopening of assessment - Non-issuance of notice u/s. 148 - Once it is proved that notice u/s.148 was not issued, there cannot be any question of making any reassessment. Reliance of CIT(A) on the provisions of section 292BB is misplaced because the said section only stipulates that participation in the assessment proceedings/reassessment proceedings would be deemed as a proper service of notice. - AT
Validity of reopening of assessment - Non-issuance of notice u/s. 148 - Once it is proved that notice u/s.148 was not issued, there cannot be any question of making any reassessment. Reliance of CIT(A) on the provisions of section 292BB is misplaced because the said section only stipulates that participation in the assessment proceedings/reassessment proceedings would be deemed as a proper service of notice. - AT
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