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    <title>2026 (5) TMI 853 - KARNATAKA HIGH COURT</title>
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    <description>An assessment based on import-discrepancy material was held unsustainable where the Department relied on incomplete CBIC data and did not share all material with the assessee. The Court applied the principle of natural justice, holding that adverse tax conclusions cannot be drawn from material affecting liability unless the assessee is given full disclosure and a meaningful opportunity to rebut it. Any further material received by the Revenue could be used only after being shared and after fresh opportunity to respond. The assessment order was therefore set aside and the matter remitted for fresh adjudication.</description>
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      <description>An assessment based on import-discrepancy material was held unsustainable where the Department relied on incomplete CBIC data and did not share all material with the assessee. The Court applied the principle of natural justice, holding that adverse tax conclusions cannot be drawn from material affecting liability unless the assessee is given full disclosure and a meaningful opportunity to rebut it. Any further material received by the Revenue could be used only after being shared and after fresh opportunity to respond. The assessment order was therefore set aside and the matter remitted for fresh adjudication.</description>
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