Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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The HC quashed and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
The HC quashed and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
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