Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Proceeds of crime and property equivalent in value: failure to explain lawful source sustains attachment; lack of required notice can vitiate confirma...
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The primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
The primary issue was whether principles of natural justice were violated by improper service of the show-cause notice and failure to physically serve notice of personal hearing. The court found the record establishes no physical service of the SCN or effective personal-hearing notice, meaning the petitioner was deprived of an opportunity to respond; the court relied on relevant precedents holding similar non-service vitiates proceedings. Consequence: the impugned orders were held to be in violation of natural justice and the petition was partly allowed, setting aside the affected orders. - HC
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