HC examined the challenge to an assessment order passed u/s 143(3) r/w s.144B on two grounds. On the first, alleging breach of natural justice, HC held against Assessee A, noting repeated show-cause notices, failure to furnish PAN, addresses, and details to establish creditworthiness, and thus no denial of fair opportunity. On the second, alleging non-compliance with mandatory faceless assessment under s.144B (effective from 01.04.2021), HC found Revenue had offered no justification for not following the faceless procedure and was silent in its counter. Holding the faceless regime mandatory, HC applied settled law, declared the assessment proceedings and order unsustainable, and quashed/set aside the impugned assessment, thereby allowing the petition on this ground in favour of Assessee A and against Revenue.
HC examined the challenge to an assessment order passed u/s 143(3) r/w s.144B on two grounds. On the first, alleging breach of natural justice, HC held against Assessee A, noting repeated show-cause notices, failure to furnish PAN, addresses, and details to establish creditworthiness, and thus no denial of fair opportunity. On the second, alleging non-compliance with mandatory faceless assessment under s.144B (effective from 01.04.2021), HC found Revenue had offered no justification for not following the faceless procedure and was silent in its counter. Holding the faceless regime mandatory, HC applied settled law, declared the assessment proceedings and order unsustainable, and quashed/set aside the impugned assessment, thereby allowing the petition on this ground in favour of Assessee A and against Revenue.
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