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Risk-based selective vessel boarding requires accurate declarations and preserves master and agent liability where physical inspections are not select...
Permanent-establishment reassessment cannot revisit scrutinised disclosures; extended reopening fails without undisclosed material facts and within st...
The HC quashed the impugned order and remitted the case back to the respondents to pass a fresh order on merits. It held that invocation of Section 144 for assessment by best judgment method was unjustified. The petitioner's claim of loss from sale of derivatives was to be re-examined, despite the return not being e-verified initially. The HC clarified that reopening u/s 148 for reassessment u/s 147 cannot be disputed afresh in the de novo proceedings.
The HC quashed the impugned order and remitted the case back to the respondents to pass a fresh order on merits. It held that invocation of Section 144 for assessment by best judgment method was unjustified. The petitioner's claim of loss from sale of derivatives was to be re-examined, despite the return not being e-verified initially. The HC clarified that reopening u/s 148 for reassessment u/s 147 cannot be disputed afresh in the de novo proceedings.
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