Tax Dispute Resolved: Procedural Defect Nullified, Assessee Granted Fair Hearing Under Section 249(4)(b)
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....ITAT determined that Section 249(4)(b) was inapplicable due to specific procedural circumstances. The tribunal found the statutory requirements for advance tax payment were not conclusively established, particularly given the ex-parte order by the Assessing Officer. Consequently, the tribunal restored the matter to CIT(A) for merit-based adjudication, directing that the assessee be provided a reasonable opportunity of hearing in the appellate proceedings. The decision effectively nullified the procedural impediment and mandated a substantive review of the underlying tax dispute, ensuring procedural fairness and comprehensive examination of the case.....