Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
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HC dismissed the appeal, finding no sufficient cause to condone the 7-month and 20-day delay in filing. Despite medical prescriptions explaining partial delay, the court held that as a partnership firm, other partners could have acted. The petitioner failed to provide a comprehensive explanation for the entire delay period. The court emphasized that statutory service through portal upload is valid, and supplementary communications are facilitative. Applying Section 107(4), the appellate authority's refusal to extend time limitation was deemed consistent with fiscal discipline and procedural mandates, warranting no judicial intervention under constitutional review.
HC dismissed the appeal, finding no sufficient cause to condone the 7-month and 20-day delay in filing. Despite medical prescriptions explaining partial delay, the court held that as a partnership firm, other partners could have acted. The petitioner failed to provide a comprehensive explanation for the entire delay period. The court emphasized that statutory service through portal upload is valid, and supplementary communications are facilitative. Applying Section 107(4), the appellate authority's refusal to extend time limitation was deemed consistent with fiscal discipline and procedural mandates, warranting no judicial intervention under constitutional review.
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