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    <title>2025 (12) TMI 1662 - DELHI HIGH COURT</title>
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    <description>The dominant issue was whether the adjudication suffered from breach of natural justice due to non-consideration of the taxpayer&#039;s reply to the SCN. The HC found that the reply had been submitted (by email and later uploaded on the portal), yet the demand was raised in a mechanical manner without addressing the reply, indicating denial of an effective opportunity of hearing; consequently, the adjudication order was set aside and the matter was remanded to the adjudicating authority for fresh consideration. Since the foundational order was vitiated, the subsequent rectification rejection was also set aside, and the writ petition was disposed of on remand.</description>
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      <link>https://www.taxtmi.com/caselaws?id=784122</link>
      <description>The dominant issue was whether the adjudication suffered from breach of natural justice due to non-consideration of the taxpayer&#039;s reply to the SCN. The HC found that the reply had been submitted (by email and later uploaded on the portal), yet the demand was raised in a mechanical manner without addressing the reply, indicating denial of an effective opportunity of hearing; consequently, the adjudication order was set aside and the matter was remanded to the adjudicating authority for fresh consideration. Since the foundational order was vitiated, the subsequent rectification rejection was also set aside, and the writ petition was disposed of on remand.</description>
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