Reasonable Cause for Late Return: penalty under section 271(1)(c) unsustainable where disclosure, audit filing and voluntary offer showed no concealme...
Failure to furnish verification reports and to grant an opportunity to address them breaches the principles of natural justice; where verification reports influenced an adjudicatory order, the affected party must receive copies and a fresh hearing before conclusions are drawn. The note emphasises that adjudicators must conduct complete verification of records, including invoices and transitional input tax credit entries, and that a hurried, post-facto opinion formed without providing verification material to the party is impermissible. Operative effect recommended: set aside the impugned order and remit for de novo consideration with production of verification reports and an opportunity to rectify TRAN-1/TRAN-2 entries.
Failure to furnish verification reports and to grant an opportunity to address them breaches the principles of natural justice; where verification reports influenced an adjudicatory order, the affected party must receive copies and a fresh hearing before conclusions are drawn. The note emphasises that adjudicators must conduct complete verification of records, including invoices and transitional input tax credit entries, and that a hurried, post-facto opinion formed without providing verification material to the party is impermissible. Operative effect recommended: set aside the impugned order and remit for de novo consideration with production of verification reports and an opportunity to rectify TRAN-1/TRAN-2 entries.
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