Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
Mechanical approval under search assessment law vitiates assessments when sanction lacks application of mind; retrospective curative provision cannot ...
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Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
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