Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Violation of principles of natural justice - The court observed that while the show-cause notice provided details for a personal hearing, including the date, time, and venue, the abbreviation 'N.A.' indicated that no such hearing was actually scheduled. The court referred to Section 75(4) of the said Act, emphasizing that an opportunity of hearing must be provided before reaching a decision under Section 73. It noted that since an adverse decision was anticipated against the petitioners, the proper officer was duty-bound to grant them a hearing, regardless of the absence of a written request.
Violation of principles of natural justice - The court observed that while the show-cause notice provided details for a personal hearing, including the date, time, and venue, the abbreviation 'N.A.' indicated that no such hearing was actually scheduled. The court referred to Section 75(4) of the said Act, emphasizing that an opportunity of hearing must be provided before reaching a decision under Section 73. It noted that since an adverse decision was anticipated against the petitioners, the proper officer was duty-bound to grant them a hearing, regardless of the absence of a written request.
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