Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Where a declarant under the SVLDRS had made a mandatory pre-deposit in a pending appeal and disclosed it in Form SVLDRS-1, the designated committee was required to give credit for such pre-deposit while determining "tax dues" and issuing Form SVLDRS-2/3. As the pre-deposit was ignored, the quantified amount in Form SVLDRS-3 was held legally unsustainable and liable to be set aside. Consequently, the impugned Form SVLDRS-3 was quashed, and the authority was directed to issue a revised Form SVLDRS-3 after adjusting the pre-deposit and to thereafter issue the discharge certificate in Form SVLDRS-4 within the stipulated time. - HC
Where a declarant under the SVLDRS had made a mandatory pre-deposit in a pending appeal and disclosed it in Form SVLDRS-1, the designated committee was required to give credit for such pre-deposit while determining "tax dues" and issuing Form SVLDRS-2/3. As the pre-deposit was ignored, the quantified amount in Form SVLDRS-3 was held legally unsustainable and liable to be set aside. Consequently, the impugned Form SVLDRS-3 was quashed, and the authority was directed to issue a revised Form SVLDRS-3 after adjusting the pre-deposit and to thereafter issue the discharge certificate in Form SVLDRS-4 within the stipulated time. - HC
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