Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
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...
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Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
Non-speaking assessment orders that do not address taxpayer submissions violate the principles of natural justice; the impugned orders confirming liability and referring to interest and penalty without reasoned findings were quashed and set aside. The respondents are directed to issue fresh show-cause notices, grant a personal hearing, and pass detailed, reasoned speaking orders expeditiously (preferably within one month of service). The court found mechanical adjudication caused prejudice and remanded the matter for fresh adjudication to cure the procedural defect.
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