Commissioner Missteps in Tax Case: Incorrect Issues Addressed Beyond Show Cause Notice for HDD Activities.

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....Classification of services - Appellant’s activities relating to Horizontal Directional Drilling (HDD) works - The learned Commissioner has erred in adjudicating the issues not raised in the SCN. - The issue of non-fulfillment of the conditions of Notification No.32/2007 is a separate and distinct issue and there has to be a specific allegation regarding the same considering the facts and circumstances of a particular case. This has indisputably not been done in the instant case. - AT....