Self-assessed import entries remain appealable, while bona fide classification disputes without misdeclaration cannot justify confiscation or penaltie...
Actual-user customs exemption conditions permit turnkey project transfers when imported windmill components are exclusively used for installation and ...
Customs offence disqualification excludes civil contraventions, preventing refusal of a private bonded warehouse licence based solely on monetary pena...
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
Validity of reopening of assessment u/s 147 - The tribunal sided with the assessee on the key issue of the legality of the re-assessment notice under section 148. It was held that the notice was invalid as it was issued without the required sanction from the competent authority as prescribed under section 151(1) of the Act after the expiry of four years from the end of the relevant assessment year. - The ITAT observed that the argument that the Taxation and Other Laws (Relaxation of Certain Provisions) Ordinance, 2020 (TOLA) extended the time limit for issuing the notice was not applicable in this case.
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