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...
Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
Where reopening rested solely on incriminating material seized in a search on another person, the special search assessment mechanism under section 153C prevailed over general reassessment under sections 147/148, and the reassessment was held bad in law. In the absence of the searched person's Assessing Officer's satisfaction note and any independent post-search material, jurisdiction under sections 147/148 could not be assumed on third-party search material alone. The objection of borrowed satisfaction was rejected because the Assessing Officer had issued notice, sought an explanation under section 148A(b), and passed a reasoned order under section 148A(d), showing independent application of mind.
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