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    <title>2021 (11) TMI 602 - KERALA HIGH COURT</title>
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    <description>Refund proceedings under the Section 104 mechanism required compliance with the prescribed virtual hearing procedure, including recording the submissions as a personal hearing record and communicating it to the appellant for verification or correction within the stipulated time. The appellate authority conducted the hearing through video conferencing but did not follow that procedure. Because the safeguards were intended to ensure fairness in virtual hearings, the non-compliance amounted to denial of a meaningful opportunity of hearing. The appellate order rejecting the refund claim was therefore vitiated by breach of natural justice and was liable to be set aside.</description>
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      <description>Refund proceedings under the Section 104 mechanism required compliance with the prescribed virtual hearing procedure, including recording the submissions as a personal hearing record and communicating it to the appellant for verification or correction within the stipulated time. The appellate authority conducted the hearing through video conferencing but did not follow that procedure. Because the safeguards were intended to ensure fairness in virtual hearings, the non-compliance amounted to denial of a meaningful opportunity of hearing. The appellate order rejecting the refund claim was therefore vitiated by breach of natural justice and was liable to be set aside.</description>
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