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...
A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
A revision under section 263 was sustained where the Assessing Officer had not made the enquiry and verification the scrutiny assessment required. The Tribunal noted that only generalized notices had been issued, with no real examination, follow-up enquiry or application of mind on the selected scrutiny issues, including expense claims, related-party payments and tax deduction defaults. It applied the principle that merely calling for details and filing them on record is not enough to constitute enquiry, and that Explanation 2(a) to section 263 applies when no proper view is formed after due examination. The assessee's contention that disclosure of details barred revision was rejected.
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