https://www.taxtmi.com/caselaws?id=198140 Material relied upon in a show cause notice cannot be withheld from the person proceeded against on the ground that it was gathered during search or derived from foreign sources. The basic requirement of natural justice is that a person facing coercive proceedings must be furnished copies of the documents and statements used against them, and merely allowing inspection is not an adequate substitute. Article 26(2) of the OECD Model Tax Convention was noted as permitting disclosure to persons concerned with assessment or prosecution. The petitioners were therefore entitled to copies of all relied-upon documents, seized material, and statements before filing their replies. en-us Mon, 08 May 2017 00:00:00 +0530 Tue, 23 Jan 2018 22:48:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=198140 Material relied upon in a show cause notice cannot be withheld from the person proceeded against on the ground that it was gathered during search or derived from foreign sources. The basic requirement of natural justice is that a person facing coercive proceedings must be furnished copies of the documents and statements used against them, and merely allowing inspection is not an adequate substitute. Article 26(2) of the OECD Model Tax Convention was noted as permitting disclosure to persons concerned with assessment or prosecution. The petitioners were therefore entitled to copies of all relied-upon documents, seized material, and statements before filing their replies. Case-Laws Income Tax Mon, 08 May 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=198140