Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
Show-cause notice under Section 124 must be a written, specific notice and a reasonable, personal opportunity of hearing is mandatory before confiscation and penalties can be imposed; waivers must be voluntary, conscious and informed, and pre-printed or non-particularised waivers cannot substitute for the statutory notice. The article distinguishes Section 28 (duty recovery) from Section 124 (confiscation and civil consequences) and concludes that permitting confiscation without compliance with Section 124 breaches natural justice; non-compliance vitiates confiscation and allows reopening by issuing a valid Section 124 notice and fresh adjudication.
Show-cause notice under Section 124 must be a written, specific notice and a reasonable, personal opportunity of hearing is mandatory before confiscation and penalties can be imposed; waivers must be voluntary, conscious and informed, and pre-printed or non-particularised waivers cannot substitute for the statutory notice. The article distinguishes Section 28 (duty recovery) from Section 124 (confiscation and civil consequences) and concludes that permitting confiscation without compliance with Section 124 breaches natural justice; non-compliance vitiates confiscation and allows reopening by issuing a valid Section 124 notice and fresh adjudication.
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