Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Palmolein classification defeated the crude-oil concession; material misdeclaration sustained recovery and confiscation, while separate false-document...
Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
Rule 138B permits physical verification of a conveyance by a proper officer authorised by the Commissioner; an authorisation-based challenge fails where the officer holds that authority and no jurisdictional defect is established. Writ jurisdiction despite an alternative statutory appeal remains confined to exceptional circumstances, including infringement of fundamental rights, breach of natural justice, lack of jurisdiction, or challenge to statutory validity. Where a fresh show-cause notice, personal hearing, consideration of the reply, and relevant detention, verification and registration-cancellation material are provided, complaints concerning relied-upon documents require appellate examination. The writ challenge to confiscation was dismissed, leaving the statutory appeal available.
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