Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
Challenge to search and seizure under the CGST regime centred on whether cash qualifies as "goods" or as "documents or books or things" under Section 67; the court held the statutory definition of goods excludes money and reading "things" ejusdem generis with "documents" and "books" limits it to evidentiary items containing information. Cash may be seized only where specific notes or currency can be shown to have direct evidentiary value traceable to taxable transactions. On the facts, authorities failed to establish evidentiary necessity; the cash was ordered de-sealed and released, while broader validity of the search was left for further affidavit exchange and hearing with interim procedural restraints.
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