Time limits for search-based assessments are a self-contained code; extension applies only with a transfer pricing reference, otherwise late orders ar...
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Failure of electronic portal upload to effectuate show-cause notices denied the petitioner effective opportunity to be heard; the HC treated effective service and audi alteram partem as determinative and set aside the impugned ex-parte orders. The court remanded both matters, granted the petitioner four weeks to file replies, and directed the Adjudicating Authority to issue personal-hearing notices communicated via registered mobile number and email. The authority must consider the filed replies and oral submissions and pass fresh orders on the SCNs after personal hearings.
Failure of electronic portal upload to effectuate show-cause notices denied the petitioner effective opportunity to be heard; the HC treated effective service and audi alteram partem as determinative and set aside the impugned ex-parte orders. The court remanded both matters, granted the petitioner four weeks to file replies, and directed the Adjudicating Authority to issue personal-hearing notices communicated via registered mobile number and email. The authority must consider the filed replies and oral submissions and pass fresh orders on the SCNs after personal hearings.
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