Post-search scrutiny assessment remains available where original assessment limitation is unexpired, permitting timely completion under regular assess...
Independent show-cause notices remain separate proceedings, while customs adjudication challenges should ordinarily follow the statutory appellate rem...
Institutional incapacity in customs settlement proceedings excludes non-functional quorum periods from statutory disposal timelines, preventing automa...
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
Jurisdiction under section 153C failed because the seized diaries and notebooks were recovered from a third person, did not name the assessee, and contained no identifying material conclusively linking the code "DD" to him. Corroboration from a contact saved as "DD Personal", Truecaller data and other digital material was held too tenuous to supply the missing nexus. Presumptions under sections 132(4A) and 292C were confined to the person from whom the documents were found and could not be transposed to the assessee without independent evidence. The notice, consequential assessment and addition were therefore unsustainable, and the Revenue's appeal was dismissed.
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