Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
Admission of additional evidence under remand rules must await a meaningful remand report; failure to do so breaches natural justice and mandates rema...
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
Condonation of delay and limitation for preferring statutory appeals was determinative: the appellate forum found repeated adjournments and that the appeal was filed after the condonable period, so the Commissioner (Appeal) correctly held the appeal time-barred and dismissed it. The tribunal applied the proviso limiting discretionary exemptions in appeals and relied on the Supreme Court precedent that the Commissioner cannot condone delay beyond the short statutory condonation window, producing dismissal on limitation grounds. Forum shopping and invocation of writ jurisdiction were noted but did not alter the limitation outcome.
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