Search-assessment proviso jurisdiction, time-barred valuation reports, and denial of cross-examination vitiate valuation-based and confession-based ad...
Proceeds of crime: provisional attachment confirmed; equivalent value attachment and acquisition date fair market value upheld, Covid exclusion preser...
Effective service requirement: officers must explore alternative service modes beyond the GST portal and afford personal hearing; non-compliance voids...
A single adjudication order creating tax and penalty liability cannot be split through separate DRC-07 notices so as to force multiple appeals or an additional pre-deposit toward penalty. The statutory appeal mechanism is satisfied by one appeal against the composite order on deposit of 10% of the disputed tax demand, without any further deposit at that stage for the penalty component. The Court permitted withdrawal of the two notices and issuance of a fresh composite DRC-07, and clarified that limitation for appeal would run from service of the fresh notice, with no further recovery pending compliance.
A single adjudication order creating tax and penalty liability cannot be split through separate DRC-07 notices so as to force multiple appeals or an additional pre-deposit toward penalty. The statutory appeal mechanism is satisfied by one appeal against the composite order on deposit of 10% of the disputed tax demand, without any further deposit at that stage for the penalty component. The Court permitted withdrawal of the two notices and issuance of a fresh composite DRC-07, and clarified that limitation for appeal would run from service of the fresh notice, with no further recovery pending compliance.
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