Tax Liability Assessed for Late Certificate of Export; Assessee Must Be Given Chance to Present Evidence.

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....Validity of refund order - Failure to get Certificate of Export in time - the revisional authority passed an order assessing the tax liability of the appellant/writ petitioner - Tax authorities are to adjudicate upon the tax liability in accordance with law. The liability to taxation in respect of assessee should not escape assessee and likewise where the assessee was not in a position to show certain evidences which impacts the tax liability, reasonable opportunity should be afforded to such assessee to bring such evidences to the notice of the tax authorities. - HC....