Natural justice requires notice before enhancing liability under SVLDRS-3; unilateral demand was set aside.

An enhanced demand under Form No. SVLDRS-3 issued without prior notice or a hearing was held unsustainable because it violated natural justice. Unilateral enhancement of liability behind the assessee's back could not stand where no show cause notice or opportunity to respond had been given. The proper course was to issue notice, or reissue the earlier form, before making a fresh determination. The enhanced demand was therefore set aside, and the matter was restored to the designated Committee for fresh action after notice and a reasonable opportunity of hearing.

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Issues: Whether the enhanced demand raised under Form No. SVLDRS-3 without prior notice or hearing was valid.

Analysis: The enhanced demand was issued behind the assessee's back without any show cause notice or opportunity of hearing. Such unilateral enhancement of liability offended the principles of natural justice. The proper course would have been to issue a notice or reissue the earlier form so that the assessee could respond before a fresh determination was made.

Conclusion: The enhanced demand was unsustainable and was set aside. The proceedings were restored before the designated Committee for fresh action after notice and reasonable opportunity to the assessee.

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