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    <title>2024 (3) TMI 394 - ALLAHABAD HIGH COURT</title>
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    <description>Validity of a notice in a tax assessment was examined where the assessee was denied oral personal hearing, breaching principles of natural justice. Relying on prior coordinate-bench precedent interpreting statutory procedure, the court held that the assessing authority must mandatorily afford personal hearing before passing an adverse assessment; an election by the assessee against hearing was held legally immaterial. Because the assessment raised an adverse tax demand and no hearing was granted, the order was set aside and the matter remitted for issuance of fresh notice and opportunity of personal hearing, enabling a reasoned reconsideration.</description>
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      <description>Validity of a notice in a tax assessment was examined where the assessee was denied oral personal hearing, breaching principles of natural justice. Relying on prior coordinate-bench precedent interpreting statutory procedure, the court held that the assessing authority must mandatorily afford personal hearing before passing an adverse assessment; an election by the assessee against hearing was held legally immaterial. Because the assessment raised an adverse tax demand and no hearing was granted, the order was set aside and the matter remitted for issuance of fresh notice and opportunity of personal hearing, enabling a reasoned reconsideration.</description>
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