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    Pre-commencement project receipts remain capital when tied to installation, while infrastructure deductions follow the taxpayer's chosen initial year.
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      Fair and effective opportunity of hearing in faceless...

      Effective hearing in faceless reassessment requires notices to reach the assessee, prompting remand for fresh assessment proceedings.

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      Income TaxJuly 16, 2026Case LawsHC
      Fair and effective opportunity of hearing in faceless reassessment requires communications to reach the assessee through its notified or registered contact details. The High Court noted that the assessee had provided an email address in its return and had another registered on the income-tax portal and MCA database, but subsequent notices were sent only to a resigned auditor's email address. As this prevented an adequate response with supporting material, the assessment order and demand notice were quashed and remanded for fresh proceedings, including a response opportunity, video-conference hearing and speaking order. The merits and validity of service under Rule 127 were left open.

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      ActsIncome Tax