https://www.taxtmi.com/caselaws?id=470022 Ex parte reassessment and first appellate proceedings may require restoration where quantum additions under Section 68 and consequential penalties were determined without an effective opportunity to present factual explanations. The notes emphasise that transactions requiring factual examination should not ordinarily be concluded without adequate hearing, particularly where substantial additions and penalties are involved. Restoration for de novo consideration preserves the assessee's opportunity to comply and present the merits, while permitting the Assessing Officer to proceed according to law if non-compliance continues. The operative subject-matter is therefore the relationship between natural justice, effective hearing, and fresh examination of quantum and penalty proceedings. en-us Thu, 13 Mar 2025 00:00:00 +0530 Mon, 13 Jul 2026 18:58:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470022 Ex parte reassessment and first appellate proceedings may require restoration where quantum additions under Section 68 and consequential penalties were determined without an effective opportunity to present factual explanations. The notes emphasise that transactions requiring factual examination should not ordinarily be concluded without adequate hearing, particularly where substantial additions and penalties are involved. Restoration for de novo consideration preserves the assessee's opportunity to comply and present the merits, while permitting the Assessing Officer to proceed according to law if non-compliance continues. The operative subject-matter is therefore the relationship between natural justice, effective hearing, and fresh examination of quantum and penalty proceedings. Case-Laws Income Tax Thu, 13 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470022