Search and seizure: abatement of earlier search bars use of prior seized material in later search-based assessments; relief limited to new documents f...
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Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
Notices issued to the email address recorded in the tax database were held valid in law; non-service cannot be attributed to the Assessing Officer where the assessee provided or allowed an inaccessible email ID, and the assessee bears the duty to furnish and monitor a valid communication address, but must still be afforded an opportunity to be heard. Where pandemic-related non-communication plausibly explains delayed compliance, delay in filing appeals to the CIT(A) was condoned and the appeals were restored for adjudication on merits, subject to a protective condition that the assessee deposit twenty percent of the demand; no fresh assessment or remand to the Assessing Officer was ordered.
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