Transferable duty credit scrips validity and bona fide transferee entitlement to exemption upheld where scrips were subsisting at import, appeals allo...
Classification of knocked down motor vehicle component imports: Notification benefit denied because items are standalone non kit parts requiring subst...
Reassessment against a deceased assessee: procedural defect mandates fresh reassessment; nonresponsive petitioner may be treated as legal representati...
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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