Revisability of return invalidation communications under tax procedure affirmed, impugned non revisional finding quashed and matter remitted for fresh...
Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
Reassessment proceedings were held to be within limitation because the first corrigendum to the section 148A(b) notice validly extended the time to respond, and that extended period had to be excluded under the third proviso to section 149(1). On that basis, the section 148A(d) order and section 148 notice were timely, and approval by the PCIT/CIT was competent rather than approval by the PCCIT/CCIT. The objection that only the Faceless Assessing Officer could issue the notice was rejected, as both the jurisdictional and faceless officers were treated as competent. The writ challenge on disputed factual issues, including claimed tax exemption and NRE account status, was not entertained, leaving those matters for the Assessing Officer.
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