Effective hearing in GST adjudication requires actual opportunity to respond; ineffective service through a former auditor invalidated ex parte procee...
Third-party search material requires special assessment route, rendering general reassessment notices without jurisdiction when it forms the proceedin...
Transfer-pricing adjustments must be confined to international associated-enterprise transactions, while functionally dissimilar comparables remain ex...
Insolvency moratorium bars income-tax revision proceedings against corporate debtors until the moratorium ends, preserving merits for later determinat...
Show-cause notice and a meaningful opportunity to respond are required before an assessment can make an addition as unexplained money. Where proposed variations notified to the taxpayer differed from the unexplained-money addition ultimately made, and no notice addressed that proposition, the taxpayer was denied an opportunity of hearing in breach of natural justice. The assessment order and consequential penalty notices were quashed, while preserving the revenue's right to commence fresh proceedings in accordance with law.
Show-cause notice and a meaningful opportunity to respond are required before an assessment can make an addition as unexplained money. Where proposed variations notified to the taxpayer differed from the unexplained-money addition ultimately made, and no notice addressed that proposition, the taxpayer was denied an opportunity of hearing in breach of natural justice. The assessment order and consequential penalty notices were quashed, while preserving the revenue's right to commence fresh proceedings in accordance with law.
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