Condonation of delay permits statutory appeal restoration where inadequate service explanation prevented consideration of reassessment and taxable-inc...
Limitation in customs appeals permits exclusion for bona fide refund proceedings, enabling restoration of Bill of Entry assessment challenges on merit...
Warehousing permission requires deposit at the designated bonded warehouse; unauthorised diversion triggers confiscation, redemption fine and importer...
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
Validity of reopening of assessment - The High Court found that the Assessing Officer issued the notice based on the survey action on Jammu & Kashmir Bank, conducted after the original assessment order. The Court concluded that the notice was not issued due to any fresh tangible material but rather on the basis of the same material already available during the original assessment proceedings. The Court noted that the discrepancies in remittance amounts were explained by the bank's practice of applying notional and actual rates during transaction processing. The High Court quashed the notice issued under Section 148 of the Income Tax Act, 1961.
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