https://www.taxtmi.com/caselaws?id=57656 In rectification proceedings, the substance of a notice prevails over its caption: a notice referring to an earlier assessment, a retrospective tax amendment, and proposed alteration of the assessment was treated as one under the rectification provision, not as an escaped-assessment notice. The opportunity of hearing requirement was satisfied by inviting written objections and considering the response, as a personal oral hearing is not always necessary. In revision, the authority's jurisdiction was confined to the legality and propriety of the order on the existing record, so it could not investigate a later refund claim that was not before the assessing authority. en-us Wed, 23 Jul 1975 00:00:00 +0530 Sat, 11 Dec 2010 13:33:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=57656 In rectification proceedings, the substance of a notice prevails over its caption: a notice referring to an earlier assessment, a retrospective tax amendment, and proposed alteration of the assessment was treated as one under the rectification provision, not as an escaped-assessment notice. The opportunity of hearing requirement was satisfied by inviting written objections and considering the response, as a personal oral hearing is not always necessary. In revision, the authority's jurisdiction was confined to the legality and propriety of the order on the existing record, so it could not investigate a later refund claim that was not before the assessing authority. Case-Laws Income Tax Wed, 23 Jul 1975 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=57656