Opportunity to respond to jurisdictional reports is mandatory before customs settlement duty enhancement; connected applications require consistent ad...
Specific customs headings for scaffolding components prevail over general classification, invalidating misclassification proceedings and enabling with...
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Reopening of assessment against entity ceased to exist/amalgamating entity - The court observed that the Revenue had not considered the income tax return filed by the petitioner that included the transactions of the amalgamated entities. The notice was thus issued without a proper examination of available records and without application of mind. Highlighting the legislative intent behind section 148A of the Income Tax Act, the court noted that the reassessment provisions aim to reduce frivolous litigation and ensure fair proceedings. The court criticized the mechanical issuance of the notice without proper scrutiny of the facts and records.
Reopening of assessment against entity ceased to exist/amalgamating entity - The court observed that the Revenue had not considered the income tax return filed by the petitioner that included the transactions of the amalgamated entities. The notice was thus issued without a proper examination of available records and without application of mind. Highlighting the legislative intent behind section 148A of the Income Tax Act, the court noted that the reassessment provisions aim to reduce frivolous litigation and ensure fair proceedings. The court criticized the mechanical issuance of the notice without proper scrutiny of the facts and records.
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