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    <title>1957 (9) TMI 86 - KERALA HIGH COURT</title>
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    <description>An income-tax assessment based on comparable cases or other external material cannot be sustained unless the assessee is first informed of the material and given a fair opportunity to explain or rebut it. Where the statement of the case did not show that the comparable cases relied on by the authorities had been disclosed before completion of assessment, the gross profit estimate founded on that material lacked fair procedure. The assessment was therefore unsupported on that basis, and the issue was answered in favour of the assessee and against the Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=284032</link>
      <description>An income-tax assessment based on comparable cases or other external material cannot be sustained unless the assessee is first informed of the material and given a fair opportunity to explain or rebut it. Where the statement of the case did not show that the comparable cases relied on by the authorities had been disclosed before completion of assessment, the gross profit estimate founded on that material lacked fair procedure. The assessment was therefore unsupported on that basis, and the issue was answered in favour of the assessee and against the Revenue.</description>
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