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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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HC held that an assessment order passed under section 143(3) read with section 144B was vitiated by breach of natural justice because the assessee was not given an effective opportunity of hearing. The authority issued a video-conferencing intimation only a few hours before the scheduled hearing, despite the assessee's request for adjournment and for a hearing after a stated date, and did not properly consider the request for reasonable time to file a reply. The assessment was set aside and the matter remanded for a fresh order after granting a meaningful opportunity of hearing, including video conferencing.
HC held that an assessment order passed under section 143(3) read with section 144B was vitiated by breach of natural justice because the assessee was not given an effective opportunity of hearing. The authority issued a video-conferencing intimation only a few hours before the scheduled hearing, despite the assessee's request for adjournment and for a hearing after a stated date, and did not properly consider the request for reasonable time to file a reply. The assessment was set aside and the matter remanded for a fresh order after granting a meaningful opportunity of hearing, including video conferencing.
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