Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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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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