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...
Export Obligation Discharge Certificates for EPCG compliance cannot be questioned by Customs unless DGFT adjudicates and cancels them, so demands quas...
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Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
Reopening of assessment is time barred where the assessee filed a return and disclosed all material facts; audit objections that merely note absence of justification in the file do not constitute fresh information to initiate reassessment if the assessing officer already possessed the relevant documents. Consequently, under the pre 1 April 2021 scheme the extended six year period is unavailable and reassessment notices issued beyond four years from the end of the assessment year are invalid; the notice dated 31.03.2023 and subsequent proceedings are therefore barred by limitation.
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