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HC held assessment order invalid due to fundamental procedural defects in implementing Faceless Assessment Scheme. Original order failed to qualify as Draft Assessment Order (DAO) under s.144C(1), lacking statutory requirements for assessee response. Department's subsequent corrigendum attempting to retroactively designate order as DAO was ineffective, as 30-day objection period under s.144C(2) had already lapsed. Court rejected Revenue's argument that errors were minor, finding them fundamental to jurisdictional validity. Demand notice under s.156 cannot be nullified through mere corrigendum. Non-compliance with s.144C statutory requirements not protected by s.292BB savings clause. Questions 1-3 answered in assessee's favor, invalidating assessment order.
HC held assessment order invalid due to fundamental procedural defects in implementing Faceless Assessment Scheme. Original order failed to qualify as Draft Assessment Order (DAO) under s.144C(1), lacking statutory requirements for assessee response. Department's subsequent corrigendum attempting to retroactively designate order as DAO was ineffective, as 30-day objection period under s.144C(2) had already lapsed. Court rejected Revenue's argument that errors were minor, finding them fundamental to jurisdictional validity. Demand notice under s.156 cannot be nullified through mere corrigendum. Non-compliance with s.144C statutory requirements not protected by s.292BB savings clause. Questions 1-3 answered in assessee's favor, invalidating assessment order.
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