https://www.taxtmi.com/article/detailed?id=12142 Notice must be correct, complete and unambiguous so the noticee can understand why the notice is issued and what response is required; if a notice contains irrelevant or inapplicable material that is not removed, the noticee may be deprived of adequate opportunity to respond and consequent proceedings or orders may be rendered vulnerable. This principle was applied in litigation over a penalty notice where a defective form of notice was treated as depriving the assessee of effective opportunity to respond, and the higher forum declined to overturn the lower fora's approach. The adequacy rule applies beyond penalty proceedings. en-us Tue, 19 Dec 2023 10:09:36 +0530 Tue, 19 Dec 2023 10:09:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=12142 Notice must be correct, complete and unambiguous so the noticee can understand why the notice is issued and what response is required; if a notice contains irrelevant or inapplicable material that is not removed, the noticee may be deprived of adequate opportunity to respond and consequent proceedings or orders may be rendered vulnerable. This principle was applied in litigation over a penalty notice where a defective form of notice was treated as depriving the assessee of effective opportunity to respond, and the higher forum declined to overturn the lower fora's approach. The adequacy rule applies beyond penalty proceedings. Articles Other Topics Tue, 19 Dec 2023 10:09:36 +0530 https://www.taxtmi.com/article/detailed?id=12142