Statute Allows Initial and Subsequent Unilateral Assessments, Followed by Bilateral Hearing to Ensure Substantive Post-Decisional Review.

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Full Text of the Document

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....The scheme of the statute itself is first allowing a unilateral assessment by the assessee, thereafter a unilateral assessment by the Assessing Officer and thereafter providing for a bilateral assessment after opportunity of hearing. - With such a statutory scheme, it cannot be said that the post decisional hearing will be farcical or a sham. - HC....