Jurisdictional validity: notice issued by a non jurisdictional officer invalidates reassessment where no formal transfer or independent verification o...
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Blocking of the petitioner's Electronic Credit Ledger under Rule 86A was held invalid because the authority neither granted a pre-decisional hearing nor recorded independent, cogent "reasons to believe" as mandated by Rule 86A. Reliance merely on enforcement reports amounted to impermissible borrowed satisfaction, and the order contained only vague assertions of ITC from non-existent suppliers and multiple e-way bills without supporting material. For breach of natural justice and non-fulfilment of statutory prerequisites, the blocking order was quashed and the petition was allowed. - HC
Blocking of the petitioner's Electronic Credit Ledger under Rule 86A was held invalid because the authority neither granted a pre-decisional hearing nor recorded independent, cogent "reasons to believe" as mandated by Rule 86A. Reliance merely on enforcement reports amounted to impermissible borrowed satisfaction, and the order contained only vague assertions of ITC from non-existent suppliers and multiple e-way bills without supporting material. For breach of natural justice and non-fulfilment of statutory prerequisites, the blocking order was quashed and the petition was allowed. - HC
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