Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
HC quashed Show Cause Notice dated June 20, 2012 and Order-in-Original dated March 26, 2024 due to inordinate delay in adjudication. The court rejected Customs Department's justification that delays resulted from repeated requests for documents and placement in Call Book. Following precedents in Swatch Group India and Vos Technologies cases, HC held that statutory timelines for adjudication are mandatory and cannot be circumvented by administrative delays. The 12-year gap between SCN issuance and adjudication, despite multiple hearings between 2012-2015, was deemed unjustified. Court emphasized that such administrative indifference harms both taxpayer interests and exchequer.
HC quashed Show Cause Notice dated June 20, 2012 and Order-in-Original dated March 26, 2024 due to inordinate delay in adjudication. The court rejected Customs Department's justification that delays resulted from repeated requests for documents and placement in Call Book. Following precedents in Swatch Group India and Vos Technologies cases, HC held that statutory timelines for adjudication are mandatory and cannot be circumvented by administrative delays. The 12-year gap between SCN issuance and adjudication, despite multiple hearings between 2012-2015, was deemed unjustified. Court emphasized that such administrative indifference harms both taxpayer interests and exchequer.
Note: It is a system-generated summary and is for quick reference only.