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Issues: Whether the faceless assessment order was prima facie affected by additions beyond the proposed variations in the show-cause notice and denial of an effective virtual personal hearing.
Analysis: The materials indicated that additions in the assessment order may exceed the variations proposed in the show-cause notice. They also indicated that no video-conferencing link or password was supplied on the scheduled hearing date despite the assessee's request, and that no further hearing opportunity appeared to have been provided before the assessment order was made. This disclosed a prima facie non-adherence to the prescribed faceless-assessment procedure and principles of natural justice.
Outcome: The matter was listed for further consideration after allowing the Revenue to obtain instructions; liberty was reserved to press the interim application if required before the next listing.