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...
ITAT condoned a 267-day delay, admitted the appeal and allowed the assessee's challenge to a revision order under s.263. Holding that the PCIT acted without independent application of mind, failed to appreciate the distinction between substantive and protective assessments and overlooked pending appellate proceedings, the Tribunal quashed the impugned s.263 order and restored the assessment framed by the AO under s.147/ s.143(3). The Tribunal found the addition under s.68 in the related entity's substantive assessment preclusive of revising the assessee's protective assessment, concluded no mala fide conduct or investigation failure, and remitted no further relief; the assessee's appeal accordingly succeeds.
ITAT condoned a 267-day delay, admitted the appeal and allowed the assessee's challenge to a revision order under s.263. Holding that the PCIT acted without independent application of mind, failed to appreciate the distinction between substantive and protective assessments and overlooked pending appellate proceedings, the Tribunal quashed the impugned s.263 order and restored the assessment framed by the AO under s.147/ s.143(3). The Tribunal found the addition under s.68 in the related entity's substantive assessment preclusive of revising the assessee's protective assessment, concluded no mala fide conduct or investigation failure, and remitted no further relief; the assessee's appeal accordingly succeeds.
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