TMI Blog2025 (1) TMI 591X X X X Extracts X X X X X X X X Extracts X X X X ..... dded Tax Rules, 2005 or not - HELD THAT:- Proviso in sub-section(1) of section 81 says that an amendment, which has effect of enhancing an assessment or otherwise increase liability of the assessee shall not be made unless the authority has given notice to the assessee of its intention to do so and has allowed the assessee a reasonable opportunity of being heard. Going by submission made on behalf ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Mishra, Advocate (Standing Counsel) JUDGMENT ARINDAM SINHA, J. 1. Mrs. Roy Choudhury, learned advocate appears on behalf of petitioner and submits, impugned is, inter alia, intimation dated 30th November, 2024 intimating that the Joint Commissioner of Sales Tax (Appeal), in its appeal order no.3623 dated 21st October, 2023 had dismissed the appeal. As such, petitioner then became liable to pay ta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... etition is demonstration that petitioner was communicated the rectification order, subject matter of the intimation. 3. So far as appeal order dated 24th April, 2023 is concerned, Mr. Mishra hands up copy of the order and attached thereto postal receipt showing dispatch to petitioner on date appearing to be sometime in July, 2023. Mr. Mishra attempts to give the date as in the postal stamp to be 4 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... it typographical error in printing date of the order mentioned in impugned intimation. Petitioner s contention is that the order mentioned in impugned intimation was not served. It could not have been as the particulars of the order themselves carry an error. However, we are convinced that petitioner was aware all along. 6. At this stage Mrs. Roy Choudhury submits, by the rectification there was e ..... X X X X Extracts X X X X X X X X Extracts X X X X
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