Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated 28.03.2022, which had become final. Therefore, there was no basis for initiating a subsequent re-assessment proceeding. The Court held that in the absence of any declaration annulling or setting aside the previous re-assessment order, the Assessing Authority lacked jurisdiction to issue the second re-assessment notice. Thus, the proceedings initiated through the notice dated 30.07.2022 were declared as without jurisdiction and nullity.
Reopening of assessment u/s 147 - second re-assessment notice u/s 148A - The High Court noted that the petitioner did not challenge the earlier re-assessment order dated 28.03.2022, which had become final. Therefore, there was no basis for initiating a subsequent re-assessment proceeding. The Court held that in the absence of any declaration annulling or setting aside the previous re-assessment order, the Assessing Authority lacked jurisdiction to issue the second re-assessment notice. Thus, the proceedings initiated through the notice dated 30.07.2022 were declared as without jurisdiction and nullity.
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