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...
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Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
Impugned proceedings u/s 147 were held invalid as the notice u/s 148 was issued beyond the time limit prescribed u/s 149. The Tribunal interpreted the amended provisions along with the explanatory memorandum to mean that if the notice was barred by limitation under the erstwhile provisions, it cannot be issued even after the amendment. Consequently, the impugned notice and proceedings were quashed for being initiated beyond the prescribed time limit u/s 149, and the decision was in favor of the assessee.
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