Alternative statutory remedy and unexplained delay barred writ review of customs confiscation adjudication, leaving merits for appellate consideration...
Authorised courier due diligence protects against penalties where declared exports conceal prohibited goods despite proper documentation and customs p...
Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.
Reopening of assessment under notice u/s.148 was invalid because the AO did not satisfy the mandatory conditions for issuing a notice beyond three years, and the reasons failed to establish escaped income exceeding the statutory threshold tied to assets/expenditure or book entries; outcome: notice and consequent assessment quashed. Approval by the prescribed authority under the sanction provision was held mechanical and without independent verification of seized material, lacking application of mind; outcome: sanction invalidated and reinforcement of notice invalidity. Search-origin evidence seized from a third party laptop was not treated as sufficient to justify reopening when statutory conditions were unmet.
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