Validity of Show Cause Notice Questioned Due to Lack of Prior Intimation u/r 142(1A) for 2017-2021 Tax Period.

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....Validity of Show Cause Notice - SCN issued straight away, without issuing a prior intimation under Rule 142 (1A) - It is a trite law that whenever any ambiguity arises with regard to any provision, the benefit must go to the tax payer. In the instant case, since admittedly the tax period related to 01.07.2017 to 31.03.2021 which covers the pre and post amended period of Rule 142(1A), the 1st respondent ought to have issued tax intimation to the petitioner under Rule 142 (1A). - HC....