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    <title>2024 (12) TMI 454 - BOMBAY HIGH COURT</title>
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    <description>A departmental audit within the CAG&#039;s statutory audit domain did not become an audit of the taxpayer merely because the taxpayer&#039;s returns were examined, so a show cause notice based on revenue discrepancies from that scrutiny was not without jurisdiction. The Court also held that allegations of pre-determination did not justify quashing at the threshold where the notice reflected prima facie consideration of material, replies, and audit observations. Extended limitation could not be faulted at the notice stage where suppression and non-declaration were alleged, and no recognised exception to the alternate-remedy rule was shown. The writ challenge therefore failed and the notice was sustained.</description>
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    <pubDate>Fri, 06 Dec 2024 00:00:00 +0530</pubDate>
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      <title>2024 (12) TMI 454 - BOMBAY HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=762874</link>
      <description>A departmental audit within the CAG&#039;s statutory audit domain did not become an audit of the taxpayer merely because the taxpayer&#039;s returns were examined, so a show cause notice based on revenue discrepancies from that scrutiny was not without jurisdiction. The Court also held that allegations of pre-determination did not justify quashing at the threshold where the notice reflected prima facie consideration of material, replies, and audit observations. Extended limitation could not be faulted at the notice stage where suppression and non-declaration were alleged, and no recognised exception to the alternate-remedy rule was shown. The writ challenge therefore failed and the notice was sustained.</description>
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