Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
Challenge concerns validity of service where notices/orders were uploaded under an inaccessible portal tab, preventing the taxpayer from responding and leading to an ex parte assessment under Section 73. The tribunal found that electronic upload in an inaccessible category did not satisfy principles of natural justice because the affected person was not given a realistic opportunity to be heard; consequent rejection of a rectification application was without reasons and vitiated. The impugned rectification rejection was quashed and the matter remitted for reconsideration, directing fresh, reasoned disposal of the rectification plea and consideration of records and explanations with opportunity to the taxpayer.
Challenge concerns validity of service where notices/orders were uploaded under an inaccessible portal tab, preventing the taxpayer from responding and leading to an ex parte assessment under Section 73. The tribunal found that electronic upload in an inaccessible category did not satisfy principles of natural justice because the affected person was not given a realistic opportunity to be heard; consequent rejection of a rectification application was without reasons and vitiated. The impugned rectification rejection was quashed and the matter remitted for reconsideration, directing fresh, reasoned disposal of the rectification plea and consideration of records and explanations with opportunity to the taxpayer.
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