2021 (2) TMI 1034

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....ernment Advocate ORDER Heard Mr.Hari Radhakrishnan, learned counsel for the petitioner and Mr.ANR.Jayaprathap, learned Government Advocate for the respondent. 2. The petitioner challenges order dated 24.08.2020 and the main ground argued is violation of principles of natural justice on the ground that the petitioner was not heard in person prior to passing of the impugned order. Reliance is pla....

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....r extending opportunity per se. 4. It is true that neither Section 73 nor Section 74 specifically require an assessing officer to extend the opportunity of personal hearing to an assessee prior to completion of proceeding. However, Section 75 of the Act, a general provision relating to the procedure to be followed in determination of tax at sub section (4) thereof, contemplates that an opportunit....