Effective notice and personal hearing requirements invalidate ex parte tax adjudication conducted without meaningful taxpayer communication.

Ex parte adjudication under Section 73(9) is invalid where the show-cause notice, reminder and order are uploaded only in the additional notices and orders tab without effective communication. The absence of a specified date, time and venue for personal hearing denies the taxable person a meaningful opportunity to respond and be heard. Such procedure violates the principles of natural justice and does not satisfy the requirement to determine liability after considering the taxpayer's representation. The article notes that the adjudication was vitiated on these grounds, in favour of the assessee.

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Issues: Whether an ex parte adjudication under Section 73(9) could stand where the show-cause notice, reminder and adjudication order were uploaded only in the additional notices and orders tab, and no date, time or venue of personal hearing was specified.

Analysis: Section 73(9) requires determination after considering the representation, if any, of the taxable person. Uploading the relevant communications only in the additional notices and orders tab did not amount to effective communication. Further, the show-cause notice and reminder did not specify the particulars of personal hearing, depriving the petitioners of an effective opportunity to reply and be heard.

Conclusion: The ex parte adjudication was vitiated by violation of the principles of natural justice and non-compliance with Section 73(9), in favour of the assessee.

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