Customs valuation and import permissibility conflict resolved: accepted enhancement of transaction value removes liability for confiscation and penalt...
Attachment and proclamation of sale of immovable property: limitation treated from financial year end; proclamation held within period, petition dismi...
Second Schedule attachment and validity of a post-notice mortgage: TRO cannot declare mortgage void ab initio; sale and appropriation allowed thereaft...
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Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
Reopening for A.Y. 2015-16 was challenged on the ground that a notice under s.148 issued after 1 April 2021 was impermissible under the post-Finance Act 2021 regime and the Revenue's own concession before the SC that such notices must be dropped. Applying that concession, and noting that the impugned s.148 notice was dated 23 April 2022, the reopening lacked legal basis; consequently, the s.148 notice and all consequential proceedings, including the assessment order, demand, penalty actions, and recovery steps, were quashed and set aside. - HC
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