Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
Reopening of assessment under the new regime requires supplying to the taxpayer the materials forming the basis for reopening; where only a notice and reasons recorded were provided without annexed material, the taxpayer was deprived of an effective opportunity to respond and the subsequent order under the new procedure was invalidated. The note emphasises that failure to furnish underlying information precludes meaningful representation and renders the reopening notice defective, aligning with higher-court guidance that materials must be disclosed before final action is taken.
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