Educational approval requires mandatory State registration, but incidental surplus and trustee-owned land do not prove private benefit or profit motiv...
Judicial review of settlement orders cannot reopen settled customs notices, while statutory interest remains subject to verification and quantificatio...
Customs Broker licence lending for consideration justified revocation where exporter authorisation and client verification obligations were also breac...
Fraudulent import documents suspend limitation protection, while redemption of confiscated goods requires duty and interest despite bona fide purchase...
ODR arbitration participation remains mandatory after failed conciliation, while jurisdictional and maintainability objections stay available before t...
Transparency in technical bid evaluation requires disclosed standards and recorded reasons; opaque scoring invalidated tender awards and required fres...
Automated export obligation extensions remove separate regional applications after committee approval for Advance Authorisation and EPCG authorisation...
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The amended reassessment regime requires exclusion of the period covered by deemed Section 148A proceedings, including the time taken to supply information and the assessee's response period, when computing limitation. Applying Ashish Agarwal, Rajeev Bansal and the limitation-extension principles recognised in TOLA/Cognizance, the Court treated the earlier notice as a deemed Section 148A(b) notice and found the Section 148A(d) order and consequential Section 148 notice issued on 30.07.2022 to be within time. On sanction, Section 151 as amended from 01.04.2021 permits approval by any authority named in clause (ii) after three years from the end of the assessment year, so approval by the Director General was sufficient.
The amended reassessment regime requires exclusion of the period covered by deemed Section 148A proceedings, including the time taken to supply information and the assessee's response period, when computing limitation. Applying Ashish Agarwal, Rajeev Bansal and the limitation-extension principles recognised in TOLA/Cognizance, the Court treated the earlier notice as a deemed Section 148A(b) notice and found the Section 148A(d) order and consequential Section 148 notice issued on 30.07.2022 to be within time. On sanction, Section 151 as amended from 01.04.2021 permits approval by any authority named in clause (ii) after three years from the end of the assessment year, so approval by the Director General was sufficient.
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