Written submissions without a conscious waiver cannot be treated as waiver of Right to be heard

Amrik Singh Bhullar Vs ITO (ITAT Chandigarh) ITAT Chandigarh thrashing three important issues of mass importance in pervasive and Omnipotence e-proceedings in tax administration held; In the light of the above different set of reasoning, the issues raised are being decided under the following sub-issues: i) Limitation ii) What would constitute record ? and iii) Can written submissions without a conscious waiver be treated as waive of Right to be heard ? LIMITATION 11.1 Addressing the first of the above issues, it is eminently clear that the conclusion that the Rectification a...