Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pe...
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
Reassessment based on the same interest income and TDS mismatch material already examined in final appellate proceedings was held to be an impermissible change of opinion. The sanction note disclosed no fresh tangible information, new ground, or subsequent material suggesting escapement of income, so reopening under Section 148 amounted to a collateral attack on a concluded determination. On that basis, the HC found the assumption of jurisdiction unsustainable and quashed the notice, sanction note, and consequential proceedings.
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