Person chargeable with duty must be the importer at importation; subsequent purchasers cannot be held liable where beneficial owner rules did not appl...
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
Reassessments reopened under the income tax reassessment provision on the basis of incriminating material discovered during searches under the search provisions are excluded from the Direct Tax Vivad Se Vishwas Scheme by operation of the statutory exclusion in Section 96; where reassessment stems from search-related material the petitioner is ineligible and the court will not read temporal cut-offs or carve-outs into the statute. Clarificatory circulars identifying search-based assessments do not displace or override the statutory exclusion and cannot bring such cases within the Scheme.
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