Year-wise GST tax periods make composite show cause notices impermissible, requiring separate proceedings despite contrary non-jurisdictional preceden...
Prior APA methodology guides transfer pricing benchmarking where consistent FAR profiles support comparability and arm's length margins eliminate adju...
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The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
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