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The ITAT held that the Assessing Officer (AO) violated statutory procedure under section 154 by failing to serve notice to the assessee before passing rectification orders for AY 2016-17, 2017-18, and 2018-19. The tribunal found a clear breach of natural justice, emphasizing that the AO cannot disregard mandatory procedural requirements. The department's argument that the notice omission caused no prejudice was rejected, with the tribunal noting such arbitrary actions offend constitutional principles of fairness. Consequently, the impugned rectification orders were set aside, upholding the assessee's right to be heard before any assessment modification.
The ITAT held that the Assessing Officer (AO) violated statutory procedure under section 154 by failing to serve notice to the assessee before passing rectification orders for AY 2016-17, 2017-18, and 2018-19. The tribunal found a clear breach of natural justice, emphasizing that the AO cannot disregard mandatory procedural requirements. The department's argument that the notice omission caused no prejudice was rejected, with the tribunal noting such arbitrary actions offend constitutional principles of fairness. Consequently, the impugned rectification orders were set aside, upholding the assessee's right to be heard before any assessment modification.
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