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ITAT held that penalty notice served on incorrect email ID violated principles of natural justice. The AO failed to provide reasonable opportunity to assessee by sending notice to wrong email address. CIT(A) prematurely passed order before office hours on the last day of filing, contravening established judicial precedents. The tribunal set aside both assessment and appellate orders, remanding the matter to AO for de novo proceedings with proper notice and opportunity for the assessee to present submissions. Appeal allowed for statistical purposes, directing fresh adjudication ensuring procedural fairness.
ITAT held that penalty notice served on incorrect email ID violated principles of natural justice. The AO failed to provide reasonable opportunity to assessee by sending notice to wrong email address. CIT(A) prematurely passed order before office hours on the last day of filing, contravening established judicial precedents. The tribunal set aside both assessment and appellate orders, remanding the matter to AO for de novo proceedings with proper notice and opportunity for the assessee to present submissions. Appeal allowed for statistical purposes, directing fresh adjudication ensuring procedural fairness.
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