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Section 144B requires service of a show-cause notice before a faceless assessment or reassessment makes a variation prejudicial to the assessee, so that an effective response can be given. A disallowance of cost of acquisition or construction made without notice proposing that variation breaches the mandatory faceless-assessment procedure and natural justice. Failure to disclose the grounds for proposed additions similarly denies a fair opportunity to respond. The resulting assessment is non-est, rendering other challenges academic and allowing the appeal.
Section 144B requires service of a show-cause notice before a faceless assessment or reassessment makes a variation prejudicial to the assessee, so that an effective response can be given. A disallowance of cost of acquisition or construction made without notice proposing that variation breaches the mandatory faceless-assessment procedure and natural justice. Failure to disclose the grounds for proposed additions similarly denies a fair opportunity to respond. The resulting assessment is non-est, rendering other challenges academic and allowing the appeal.
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