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    <title>1971 (9) TMI 179 - MADRAS HIGH COURT</title>
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    <description>A pre-assessment notice issued in best judgment assessment was held to require a real and effective opportunity to object. Although the assessee filed objections, the hearing was not meaningful because the account books and seized records needed to answer the proposal remained with the department for a substantial period. The HC treated a merely formal chance to reply as an empty formality and held that a quasi-judicial taxing authority must give the affected person a fair opportunity to meet the material relied on. The later demand notices could not stand, and a fresh opportunity to object was required before further action.</description>
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    <pubDate>Thu, 02 Sep 1971 00:00:00 +0530</pubDate>
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      <title>1971 (9) TMI 179 - MADRAS HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=150262</link>
      <description>A pre-assessment notice issued in best judgment assessment was held to require a real and effective opportunity to object. Although the assessee filed objections, the hearing was not meaningful because the account books and seized records needed to answer the proposal remained with the department for a substantial period. The HC treated a merely formal chance to reply as an empty formality and held that a quasi-judicial taxing authority must give the affected person a fair opportunity to meet the material relied on. The later demand notices could not stand, and a fresh opportunity to object was required before further action.</description>
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      <pubDate>Thu, 02 Sep 1971 00:00:00 +0530</pubDate>
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