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...
Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
Section 153C proceedings were held time-barred because the satisfaction note relating to the searched person had not been recorded immediately after completion of that person's assessment. Applying Calcutta Knitwears, the Court held that "immediately" means at once after completion of the searched person's assessment, not merely within a reasonable time, and that the relevant delay is measured from that completion date. A delay of about 21 months was found incapable of satisfying the statutory requirement. The notices issued under section 153C, together with the consequential notices and orders, were quashed as unsustainable in law.
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