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2024 (7) TMI 175

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..... impugned order travels beyond the scope of the SCN - Violation of principles of natural justice - HELD THAT:- On examining the summary of show cause notice and detailed notice, it is clear that the detailed notice deals with eleven tax proposals. The said eleven tax proposals correspond to those specified in the earlier intimation. It is, however, noticeable that there was no proposal with regard .....

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..... oner : Mr.B.Sivaraman For the Respondent : Mr.C.Harsha Raj, AGP (T) ORDER An order in original dated 06.02.2024 in respect of assessment period 2020-2021 is challenged both on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits and on the ground that the impugned order travels beyond the scope of the show cause notice. An intimation dated 13.09. .....

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..... detailed notice did not refer to interest or penalty liability, whereas the impugned order imposes such liability. 3. Mr.C.Harsha Raj, learned Additional Government Pleader, accepts notice for the respondent. He points out that these proceedings arose out of an inspection conducted in March 2023. He also submits that principles of natural justice were complied with by issuing intimation dated 13. .....

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..... es to remit 10% of the disputed tax demand as a condition for remand. 5. For reasons set out above, the impugned order dated 06.02.2024 shall be treated as a show cause notice and the petitioner is permitted to respond thereto within four weeks from the date of receipt of a copy of this order. The petitioner shall also remit 10% of the disputed tax demand within the aforesaid period. Upon receipt .....

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