Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
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Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
Reopening under reassessment provisions was upheld where the Assessing Officer relied on tangible seized material, printouts and a statement recorded during GST proceedings plus information from a third party, providing a prima facie basis to form belief that income escaped assessment; retraction of the statement did not, absent evidence of coercion, negate the seized material and did not vitiate the reopening. The revenue's adoption of the valuation determined by CGST/Central Excise was accepted in the assessee's hands, and a conservative job work charge at the lower end of the 4%-12% market range (adjusted for diamonds) was sustained.
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