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Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.
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