Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Reassessment beyond three years requires books of account, documents or other evidence revealing income escapement; an audit objection alone is an opinion and cannot satisfy this condition or justify review of concluded scrutiny assessments. Re-examination of already disclosed material, including limited-scrutiny records, constitutes a change of opinion, rendering reassessment proceedings time-barred and without jurisdiction. Writ jurisdiction may be invoked on admitted material to challenge a reassessment notice lacking jurisdiction despite an alternative statutory remedy or completion of reassessment. Excise-duty refunds under an industrial incentive scheme for establishing a new undertaking are capital receipts, while goodwill arising on amalgamation qualifies as a depreciable business or commercial right.
Reassessment beyond three years requires books of account, documents or other evidence revealing income escapement; an audit objection alone is an opinion and cannot satisfy this condition or justify review of concluded scrutiny assessments. Re-examination of already disclosed material, including limited-scrutiny records, constitutes a change of opinion, rendering reassessment proceedings time-barred and without jurisdiction. Writ jurisdiction may be invoked on admitted material to challenge a reassessment notice lacking jurisdiction despite an alternative statutory remedy or completion of reassessment. Excise-duty refunds under an industrial incentive scheme for establishing a new undertaking are capital receipts, while goodwill arising on amalgamation qualifies as a depreciable business or commercial right.
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