Where a faceless reassessment effectively operates as a best...

Where a faceless reassessment effectively operates as a best judgment assessment because the assessee does not comply with section 142(1) notices and does not adequately to section 144 show-cause notices, the Commissioner (Appeals) may set aside the matter and remit it for fresh assessment. The Tribunal noted that the proviso to section 251(1)(a), inserted from 1 October 2024, expressly permits such a remand in appeals against orders made under section 144. As additional evidence in the form of e-way bills had been filed and the assessee alleged inadequate opportunity, the remand was held proper. The Revenue's challenge failed and the remand order was upheld.

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