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Faceless assessment notice must cover specific prejudicial variations; unexplained final additions without notice breach section 144B and natural justice.
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Faceless assessment requires a mandatory show cause notice under section 144B(1)(xii) specifying each variation prejudicial to the assessee. Where the notice proposed only an ad hoc income estimate at 8% of turnover, but the final assessment instead made separate additions for unsecured loans and disallowances of interest and other expenses, the statutory notice requirement was not satisfied. Those final variations were not covered by the notice, so the assessment proceeded in breach of section 144B(1)(xii) and natural justice. The Tribunal sustained deletion of the additions and disallowances and dismissed the Revenue's challenge.
Faceless assessment requires a mandatory show cause notice under section 144B(1)(xii) specifying each variation prejudicial to the assessee. Where the notice proposed only an ad hoc income estimate at 8% of turnover, but the final assessment instead made separate additions for unsecured loans and disallowances of interest and other expenses, the statutory notice requirement was not satisfied. Those final variations were not covered by the notice, so the assessment proceeded in breach of section 144B(1)(xii) and natural justice. The Tribunal sustained deletion of the additions and disallowances and dismissed the Revenue's challenge.
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