Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Exclusion of limitation period: pandemic suspension plus debtor acknowledgement can extend limitation, requiring fresh factfinding on guarantee invoca...
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The HC held that an appellate authority must pass a reasoned order dealing with the grounds raised in the appeal memo, including objections based on natural justice and the request for personal hearing. Dismissing the appeal solely because the appellant was not personally present did not discharge that duty, especially where the appeal alleged breach of Section 75(4) and prejudice from administrative lapse. The appellate order was quashed and the matter remanded for fresh decision after giving an opportunity of hearing, with a direction to consider the grounds even if the appellant again does not appear.
The HC held that an appellate authority must pass a reasoned order dealing with the grounds raised in the appeal memo, including objections based on natural justice and the request for personal hearing. Dismissing the appeal solely because the appellant was not personally present did not discharge that duty, especially where the appeal alleged breach of Section 75(4) and prejudice from administrative lapse. The appellate order was quashed and the matter remanded for fresh decision after giving an opportunity of hearing, with a direction to consider the grounds even if the appellant again does not appear.
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