Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Section 144B requires a personal hearing in a faceless...
Faceless assessment safeguards require requested personal hearings and adequate final show-cause response time, failing which reassessment is required.
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Section 144B requires a personal hearing in a faceless assessment when the assessee specifically requests one; refusal breaches the statutory procedure and principles of natural justice. The applicable standard operating procedure ordinarily requires at least seven days to answer a final show-cause notice, unless curtailment is necessary because of the assessment limitation date. Without reasons for a shorter period, the response opportunity is inadequate. Denial of either safeguard resulted in quashing of the assessment, consequential demand and penalty proceedings, with fresh assessment directed after granting a hearing and opportunity for further submissions.
Section 144B requires a personal hearing in a faceless assessment when the assessee specifically requests one; refusal breaches the statutory procedure and principles of natural justice. The applicable standard operating procedure ordinarily requires at least seven days to answer a final show-cause notice, unless curtailment is necessary because of the assessment limitation date. Without reasons for a shorter period, the response opportunity is inadequate. Denial of either safeguard resulted in quashing of the assessment, consequential demand and penalty proceedings, with fresh assessment directed after granting a hearing and opportunity for further submissions.
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