Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Customs jurisdiction defined for Principal Commissioner, Vishakhapatnam, covering specified ports, districts and India's adjacent EEZ; effective on pu...
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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