Right to be heard in penalty proceedings: prior supervisory approval and Assessing Officer notice ensure procedural safeguards.

An assessee must be heard or given a reasonable opportunity to be heard before any penalty order is made; specified supervisory prior approval is required for penalty orders that exceed prescribed monetary thresholds, with different tiers of approval tied to officer rank; and when the issuing authority is not the Assessing Officer, a copy of the penalty order must be sent to the Assessing Officer.

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