Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
A Board circular prescribing a time limit for post-export amendment of shipping bills was treated as non-binding where the restriction did not arise from the governing statutory provision. On that basis, amendment and conversion of free shipping bills into drawback shipping bills were upheld, and the adjudicating authority's allowance of the change was found proper. The Tribunal therefore rejected the Revenue's challenge based solely on alleged non-compliance with the circular's time limit and sustained the conversion of the shipping bills.
A Board circular prescribing a time limit for post-export amendment of shipping bills was treated as non-binding where the restriction did not arise from the governing statutory provision. On that basis, amendment and conversion of free shipping bills into drawback shipping bills were upheld, and the adjudicating authority's allowance of the change was found proper. The Tribunal therefore rejected the Revenue's challenge based solely on alleged non-compliance with the circular's time limit and sustained the conversion of the shipping bills.
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