Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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HC allowed the petition challenging a rectification order, finding procedural violations of natural justice. The court held that when a rectification application is rejected, the authority must provide reasoned order and opportunity of hearing to the applicant. The impugned order dated 28.03.2025 was set aside, directing the respondent to reconsider the rectification application afresh, provide notice to the petitioner, and pass appropriate orders in accordance with legal principles, particularly Section 161's third proviso mandating hearing when an order adversely affects an assessee.
HC allowed the petition challenging a rectification order, finding procedural violations of natural justice. The court held that when a rectification application is rejected, the authority must provide reasoned order and opportunity of hearing to the applicant. The impugned order dated 28.03.2025 was set aside, directing the respondent to reconsider the rectification application afresh, provide notice to the petitioner, and pass appropriate orders in accordance with legal principles, particularly Section 161's third proviso mandating hearing when an order adversely affects an assessee.
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