Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
Benami property exclusion from the insolvency estate: Benami Act proceedings preclude IBC tribunals from reopening attachments or treating such assets...
Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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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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