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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Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
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