Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
Reopening of assessment u/s 147 - The Tribunal found the reassessment proceedings to be invalid due to the non-application of mind by the AO and lack of valid approval as mandated by law. Specifically, the court noted that objections filed by the assessee were not disposed of in accordance with legal requirements, and the sanction under section 151 of the Act did not bear the signature of the PCIT, rendering the initiation of reassessment proceedings invalid.
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