Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Extension or rejection of the warehousing period under the sufficient-cause standard is quasi-judicial, requiring a judicial approach and an opportunity of hearing. The notes state that a denial must follow adjudicatory proceedings and be communicated through an appealable, reasoned order. Communications that merely convey rejection without findings or justification do not satisfy principles of natural justice. The Supreme Court's COVID-19 limitation extension is also noted. On the stated facts, the rejection communications were considered prima facie unsustainable; the matter was remanded for fresh adjudication after disclosure of proposed reasons, opportunity to reply and personal hearing, while consequential proceedings remained in abeyance.
Extension or rejection of the warehousing period under the sufficient-cause standard is quasi-judicial, requiring a judicial approach and an opportunity of hearing. The notes state that a denial must follow adjudicatory proceedings and be communicated through an appealable, reasoned order. Communications that merely convey rejection without findings or justification do not satisfy principles of natural justice. The Supreme Court's COVID-19 limitation extension is also noted. On the stated facts, the rejection communications were considered prima facie unsustainable; the matter was remanded for fresh adjudication after disclosure of proposed reasons, opportunity to reply and personal hearing, while consequential proceedings remained in abeyance.
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