Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
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A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
A taxpayer showing prima facie prior payment of the same tax amount was entitled to place proof before the proper officer through a rectification application before any recovery action was taken. Where the revenue could not dispute that the receipt corresponded to the amount later treated as short-paid, the court directed verification in accordance with law to avoid double recovery of tax already paid. The petitioner was permitted to file the rectification application within the time granted, and the proper officer was required to consider it within a reasonable period.
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