https://www.taxtmi.com/caselaws?id=152208 Rectification that enhances an income-tax assessment requires notice and a reasonable opportunity of hearing to the assessee; without that safeguard, the enhancement is vitiated by breach of natural justice. The same hearing requirement applies where penal interest is increased through rectification, because the assessee must be able to meet the proposed liability. The discretionary power to reduce or waive interest under the proviso to section 18A(6) read with rule 48 was also treated as applicable to penal interest cases under section 18A(8), including default situations where no advance tax was paid. Denial of hearing wrongly excluded consideration of that relief. en-us Fri, 12 Oct 1962 00:00:00 +0530 Mon, 25 Aug 2025 11:18:17 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=152208 Rectification that enhances an income-tax assessment requires notice and a reasonable opportunity of hearing to the assessee; without that safeguard, the enhancement is vitiated by breach of natural justice. The same hearing requirement applies where penal interest is increased through rectification, because the assessee must be able to meet the proposed liability. The discretionary power to reduce or waive interest under the proviso to section 18A(6) read with rule 48 was also treated as applicable to penal interest cases under section 18A(8), including default situations where no advance tax was paid. Denial of hearing wrongly excluded consideration of that relief. Case-Laws Income Tax Fri, 12 Oct 1962 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=152208