Court Rules SCN Required for Extended Tax Liability; Oral Communication Insufficient u/s 73(1) Proviso.

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....Non-issuance of SCN - Oral intimation of tax liability during audit - Waiver of SCN not accepted by the assessee - As such limitation for the extended period is not invokable unless show cause notice puts the Assessee to notice specifically as to various commissions/omissions stated in the proviso to Section 73[1] of the Act had been committed. - HC....