https://www.taxtmi.com/caselaws?id=787715 Effective opportunity of hearing in faceless appellate proceedings requires examination of whether an assessee's failure to respond to electronic notices was bona fide before claims are rejected without merits review. Where asserted illiteracy and unfamiliarity with digital communication plausibly explain non-response, substantial justice should prevail over technical lapse absent mala fides. The appellate order was set aside and the matter restored for fresh adjudication, requiring verification of housing-loan sanction documents, bank certificates and interest certificates. The assessee received a final reasonable opportunity to submit evidence, with further non-cooperation liable to invite an adverse inference. en-us Mon, 23 Feb 2026 00:00:00 +0530 Wed, 11 Mar 2026 08:17:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787715 Effective opportunity of hearing in faceless appellate proceedings requires examination of whether an assessee's failure to respond to electronic notices was bona fide before claims are rejected without merits review. Where asserted illiteracy and unfamiliarity with digital communication plausibly explain non-response, substantial justice should prevail over technical lapse absent mala fides. The appellate order was set aside and the matter restored for fresh adjudication, requiring verification of housing-loan sanction documents, bank certificates and interest certificates. The assessee received a final reasonable opportunity to submit evidence, with further non-cooperation liable to invite an adverse inference. Case-Laws Income Tax Mon, 23 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787715