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Customs Broker licence proceedings require accurate procedural facts before delay or natural-justice findings can justify setting aside regulatory act...
Provisional assessment finalisation must precede export duty recovery, while redemption fine fails for goods already exported and unavailable for conf...
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
Where reassessment was triggered by documents found in a search on a third party, the Revenue had to proceed under the special search-assessment mechanism for "other person" cases and could not invoke general reassessment under section 147 on the same material. The Tribunal held that assumption of jurisdiction under section 147 was invalid because the very basis of action arose from third-party search material, and the reassessment was therefore vitiated. The remaining grounds were treated as academic, and the reassessment proceedings were quashed.
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