Court quashes Assessment Order for procedural irregularities.

The Court quashed the Assessment Order dated 23/06/2021, along with the related notices of demand and show-cause notice, due to the absence of a show-cause notice and failure to issue a draft assessment order as required by Section 144B of the Income Tax Act, 1961. The Respondents were directed to take necessary actions, and the Court emphasized that its decision was based on procedural irregularities without delving into the case's merits. The Petition was disposed of without imposing any costs.

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Issues: Impugning Assessment Order for lack of natural justice and show-cause notice compliance under Section 144B of the Income Tax Act, 1961.

Analysis:
1. The Petitioner challenged an Assessment Order dated 23/06/2021 and the related notices of demand, alleging a violation of natural justice principles and the absence of a show-cause notice with a draft Assessment Order as mandated by Section 144B of the Income Tax Act, 1961.

2. The Respondents submitted an Affidavit by a Deputy Commissioner, acknowledging the absence of a show-cause notice in the assessment order and expressing uncertainty about the failure to issue a draft assessment order by the faceless assessment center.

3. The Court, noting the Respondents' admission, quashed the impugned order dated 23/06/2021 along with the consequential notice of demand and show-cause notice issued under Section 274 read with 270A of the Income Tax Act, 1961. The Respondents were directed to take appropriate actions as per legal advice.

4. Importantly, the Court clarified that it refrained from making any observations on the merits of the case, focusing solely on the procedural irregularities raised by the Petitioner.

5. Finally, the Petition was disposed of without any cost implications, signifying a resolution solely based on the procedural lapses identified in the Assessment Order and related notices.

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