Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Retrospective cancellation of registration was found invalid because the Show Cause Notice lacked reasons supporting retrospective action and the petitioner was not placed on prior notice; that defect rendered the impugned order void. The review petition sought to reopen arguments already concluded in adjudication, but review jurisdiction cannot serve as an original hearing; therefore reopening overruled contentions was impermissible. The court found no manifest or material error on the face of the record amounting to a miscarriage of justice and accordingly dismissed the review petition.
Retrospective cancellation of registration was found invalid because the Show Cause Notice lacked reasons supporting retrospective action and the petitioner was not placed on prior notice; that defect rendered the impugned order void. The review petition sought to reopen arguments already concluded in adjudication, but review jurisdiction cannot serve as an original hearing; therefore reopening overruled contentions was impermissible. The court found no manifest or material error on the face of the record amounting to a miscarriage of justice and accordingly dismissed the review petition.
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