Opportunity of being heard required before tax assessments; show-cause notice and specified hearing date mandated under amendment. Amendment requires that an assessment under section 144 'shall, after giving the assessee an opportunity of being heard, make the assessment,' substitutes the reference to the initial notice provision under the return-filing regime, omits language treating amounts as refundable to the assessee, and adds provisos: the Assessing Officer must serve a show-cause notice specifying date and time to allow the assessee to be heard, and that such opportunity is unnecessary where a prior inquiry notice has been issued before making the assessment.
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Provisions expressly mentioned in the judgment/order text.
Opportunity of being heard required before tax assessments; show-cause notice and specified hearing date mandated under amendment.
Amendment requires that an assessment under section 144 "shall, after giving the assessee an opportunity of being heard, make the assessment," substitutes the reference to the initial notice provision under the return-filing regime, omits language treating amounts as refundable to the assessee, and adds provisos: the Assessing Officer must serve a show-cause notice specifying date and time to allow the assessee to be heard, and that such opportunity is unnecessary where a prior inquiry notice has been issued before making the assessment.
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