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Post-death GST liability permits fresh proceedings against legal representatives, while discontinued-business recovery remains limited to the inherite...
Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
The note contrasts the scope of reopening under Section 147 with proceedings under Section 148A, stating that 148A requires only prima facie satisfaction to initiate reassessment while Section 147 involves final determination on escapement of income. It records the principle that cross examination of a person whose statement under search proceedings is relied upon is not mandatory at the 148A stage but becomes necessary when issuing a Section 147 order if that statement is the basis for reassessment. An Assessing Officer inviting a witness for cross examination at the 148A stage does not convert that invitation into a statutory obligation; the petitioner may be afforded cross examination in subsequent proceedings.
The note contrasts the scope of reopening under Section 147 with proceedings under Section 148A, stating that 148A requires only prima facie satisfaction to initiate reassessment while Section 147 involves final determination on escapement of income. It records the principle that cross examination of a person whose statement under search proceedings is relied upon is not mandatory at the 148A stage but becomes necessary when issuing a Section 147 order if that statement is the basis for reassessment. An Assessing Officer inviting a witness for cross examination at the 148A stage does not convert that invitation into a statutory obligation; the petitioner may be afforded cross examination in subsequent proceedings.
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