Faceless assessment procedure and change of Assessing Officer found to breach natural justice; impugned assessment order quashed.

Faceless assessment procedure and change of Assessing Officer raised issues of jurisdiction and breach of natural justice; the jurisdictional AO intervening after remand was found unnecessary, rendering the subsequent hearing ineffective and constituting a violation of fair hearing given extremely limited notice, with the result that non-compliance with prior remand directions precluded further remand. The impugned assessment order passed after these procedural defects was quashed and set aside as recorded in the text.

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Issues: Whether the Assessment Order dated 10.12.2024 passed under Section 143(3) read with Section 260 and 144B of the Income-tax Act, 1961 should be quashed on the grounds that (i) the respondents failed to comply with this Court's direction to pass a de novo assessment within 12 weeks, and (ii) the assessment proceedings involved improper change/transfer of Assessing Officers and inadequate opportunity of hearing thereby violating principles of natural justice.

Analysis: The prior direction required a fresh de novo assessment to be completed within 12 weeks after affording a fresh opportunity of hearing through video conferencing. The respondents admitted non-compliance with the 12-week timeline and did not seek extension from the Court. The assessment process shows intervention by the Jurisdictional Assessing Officer after remand although the Faceless Assessing Officer was the officer directed to pass the fresh order. The Faceless Assessing Officer later issued a show-cause notice allowing only one day to reply and the change of officers and compressed timeline resulted in extensive filings by the petitioner and a hearing, but the overall procedure did not adhere to the temporal directive. The record of communications and transfer requests indicates delay and procedural irregularity in transferring the case to the Faceless Assessment Officer, causing the assessment to be completed beyond the mandated period. The one-day time given to file submissions, following the sudden takeover by a different assessing authority, raised concerns of inadequate opportunity of hearing and procedural fairness.

Conclusion: The Assessment Order dated 10.12.2024 is quashed and set aside for failure to comply with the Court's direction to complete de novo assessment within 12 weeks and for procedural irregularities including improper change of assessing officers and inadequate opportunity of hearing, resulting in violation of principles of natural justice.

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