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AI Drafter - (New and Powerful) ✕
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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AI Drafter - (New and Powerful) ✕ Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
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Issues: Whether the demand and penalty imposed on the petitioner were liable to be set aside for denial of a proper opportunity of hearing and whether the matter required fresh adjudication.
Analysis: The hearing notices were found to have been dispatched after the scheduled hearing, and the petitioner's replies showed that disputed grounds had been raised against the proposed demand and liability. In these circumstances, the petitioner had not been afforded a fair opportunity to present its case before the adjudicating authority.
Conclusion: The demand and penalty qua the petitioner were set aside, and the petitioner was directed to appear before the adjudicating authority with its replies and supporting material for fresh consideration in accordance with law.
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