Assessment time-barred u/s 153 due to missing competent-authority reference for Singapore exchange of information; assessment disallowed as barred by ...
Imported menthol-scented sweet supari classification dispute: seizure quashed, release for home consumption subject to duty bond; bank guarantee refus...
Filing a refund application within two years under Section 54 is a mandatory statutory limitation that bars the proper officer from entertaining belated claims; the absence of any provision to condone delay means the officer lacks jurisdiction except where the statute permits relief. Where the Act provides no remedy, a writ under Article 226 may be entertained to seek condonation of delay, subject to consideration of laches and bona fides. Any judicial condonation must be conditional: the taxpayer may obtain relief only if a corresponding extension is granted to enable the authorities to invoke and apply consequential remedial assessment provisions; on the facts delay was condoned.
Filing a refund application within two years under Section 54 is a mandatory statutory limitation that bars the proper officer from entertaining belated claims; the absence of any provision to condone delay means the officer lacks jurisdiction except where the statute permits relief. Where the Act provides no remedy, a writ under Article 226 may be entertained to seek condonation of delay, subject to consideration of laches and bona fides. Any judicial condonation must be conditional: the taxpayer may obtain relief only if a corresponding extension is granted to enable the authorities to invoke and apply consequential remedial assessment provisions; on the facts delay was condoned.
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