Timely pronouncement of reserved judgments requires defined timelines, transparency measures, and remedial pathways to protect liberty and effective j...
Settlement-price depression requires proof of manipulation, not merely short exposure, late selling, or below-market orders, preserving disclosure pen...
Income Declaration Scheme declarations can evidence share-capital sources, while round-tripped funds and cash-linked credits require further verificat...
Permanent establishment tests: independent subsidiary premises and principal-to-principal dealings did not create Indian taxability for offshore suppl...
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Faceless assessment must comply with principles of natural justice by providing precise notice and a reasonable opportunity to respond before an adverse quasi-judicial order affecting civil consequences is issued. Allowing less than three working days to respond was treated as inadequate where the assessee could not upload material on the portal and instead emailed a reply and supporting documents. Disregarding material acknowledged as forwarded to the Assessment Unit, and recording non-compliance contrary to the record, caused serious prejudice. The assessment order was quashed and remanded for fresh assessment after reasonable hearing and consideration of the response and documents already submitted.
Faceless assessment must comply with principles of natural justice by providing precise notice and a reasonable opportunity to respond before an adverse quasi-judicial order affecting civil consequences is issued. Allowing less than three working days to respond was treated as inadequate where the assessee could not upload material on the portal and instead emailed a reply and supporting documents. Disregarding material acknowledged as forwarded to the Assessment Unit, and recording non-compliance contrary to the record, caused serious prejudice. The assessment order was quashed and remanded for fresh assessment after reasonable hearing and consideration of the response and documents already submitted.
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