Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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A writ challenge to long-pending show cause notices was declined because the petitioners approached the High Court after about eighteen years, showing delay and laches. The Court noted that opportunities and hearing dates had been given after issuance of the notices, but the petitioners did not participate, so the delay in adjudication could not be blamed solely on the department. As factual issues still had to be examined by the competent authority, the Court refused to quash the notices at the writ stage and left all merits open. The petitions were dismissed, with liberty to appear before the authority and raise all available submissions.
A writ challenge to long-pending show cause notices was declined because the petitioners approached the High Court after about eighteen years, showing delay and laches. The Court noted that opportunities and hearing dates had been given after issuance of the notices, but the petitioners did not participate, so the delay in adjudication could not be blamed solely on the department. As factual issues still had to be examined by the competent authority, the Court refused to quash the notices at the writ stage and left all merits open. The petitions were dismissed, with liberty to appear before the authority and raise all available submissions.
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