Transfer-pricing comparability filters require fresh arm's-length analysis, while delayed receivables need separate reconsideration with working-capit...
Section 153C jurisdiction requires timely deemed search and assessee-specific satisfaction material; otherwise reassessment must use the proper statut...
Credit-note turnover adjustments preserve inverted-duty refunds, while ministerial re-computation does not constitute an impermissible appellate reman...
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Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
Faceless assessment procedures must provide the NFAC-prescribed minimum seven working days for a response and a meaningful opportunity of personal hearing. Allowing only one working day to reply, scheduling a hearing within less than 24 hours and before the reply deadline, and refusing a reasonable one-day adjournment denied natural justice. The assessment order, demand and penalty show-cause notices were quashed, with proceedings remanded to the show-cause-notice stage for fresh reply and hearing opportunities. Merits and other challenges remained open.
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