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HC held that no draft penalty order was generated under faceless assessment mechanism as required u/s 144B. The demand notice u/s 156 was improperly communicated, rendering the refund adjustment u/s 245 illegal. The court quashed the refund adjustment and remanded the matter, directing respondents to permit petitioner to file reply to show cause notice u/s 271(1)(c), generate draft penalty order after considering objections, and provide opportunity of hearing if requested.
HC held that no draft penalty order was generated under faceless assessment mechanism as required u/s 144B. The demand notice u/s 156 was improperly communicated, rendering the refund adjustment u/s 245 illegal. The court quashed the refund adjustment and remanded the matter, directing respondents to permit petitioner to file reply to show cause notice u/s 271(1)(c), generate draft penalty order after considering objections, and provide opportunity of hearing if requested.
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