Mis-declaration in import descriptions must be deliberate to justify confiscation; withheld contemporaneous import documents invalidate value redeterm...
Liability for EPCG export shortfall: duty and interest sustained, but confiscation and penalties quashed where no fraud and causes beyond importer con...
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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