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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Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
Delay and laches barred interference under Article 226 where the petitioner failed to respond properly to the discrepancy notice and show cause notice, did not furnish invoice details before the statutory authority, and raised supplier certificates only belatedly despite their earlier availability. The High Court found no justifiable basis to reopen an assessment that had already attained finality, particularly in view of the prolonged delay and the petitioner's negligence in the statutory proceedings. The writ petition was dismissed and the assessment order left undisturbed.
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