Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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.
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
