https://www.taxtmi.com/caselaws?id=128396 A notice period shorter than the usual 30 days may still satisfy the statutory requirement of a reasonable opportunity to be heard if the assessee had prior notice and sufficient time to appear; on those facts, the assessment was upheld. Penalty, however, could not be sustained where the statute made prior approval of the Commissioner a condition precedent and that approval was given only by the Assistant Commissioner. Rule 67 could not override the statutory approval requirement under section 16, so the penalty was set aside while the assessment remained valid. en-us Fri, 27 Oct 1961 00:00:00 +0530 Thu, 04 Apr 2013 12:52:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=128396 A notice period shorter than the usual 30 days may still satisfy the statutory requirement of a reasonable opportunity to be heard if the assessee had prior notice and sufficient time to appear; on those facts, the assessment was upheld. Penalty, however, could not be sustained where the statute made prior approval of the Commissioner a condition precedent and that approval was given only by the Assistant Commissioner. Rule 67 could not override the statutory approval requirement under section 16, so the penalty was set aside while the assessment remained valid. Case-Laws VAT and Sales Tax Fri, 27 Oct 1961 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=128396