2021 (9) TMI 515

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....ction 143(3) read with section 144B for Assessment Year [AY] 2018-19, notice of demand issued under section 156 as well as notice for initiation of penalty proceeding under section 270A of the Act and all proceedings initiated pursuant thereto. 3. Learned senior counsel for the Petitioner states that the Respondent No.1 issued show cause notice requiring the Petitioner to show-cause by 23:59 hours on 25th April 2021 as to why assessment should not be completed as per draft assessment order. He further states that considering that the issues were numerous and factual, the Petitioner in response to the show-cause notice-cum-draft assessment order, made specific request for personal hearing under the specific tab/ column 'VC' in terms of Sect....

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....ling upon him to show-cause as to why the assessment should not be completed as per the such draft or final draft or revised draft assessment order, the assessee or his authorised representative, as the case may be, may request for personal hearing so as to make his oral submissions or present his case before the income-tax authority in any unit; (viii) the Chief Commissioner or the Director General, in charge of the Regional Faceless Assessment Centre, under which the concerned unit is set up, may approve the request for personal hearing referred to in clause (vii) if he is of the opinion that the request is covered by the circumstances referred to in sub-clause (h) of clause (xii); xxxx xxxx xxxx xxxx (xii) the Principal Chi....

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..../revenue from the obligation cast upon it, to consider the request made for grant of personal hearing. Besides this, under sub-clause (h) of Section 144B (7)(xii) read with Section 144B(7) (viii), the respondent/revenue has been given the power to frame standards, procedures and processes for approving the request made for according personal hearing to an assessee who makes a request qua the same. 11.5. In several matters, we have asked the counsels for the revenue as to, whether any standards, procedures and processes have been framed for dealing with such requests. The response, which we have got from the standing counsels including Mr. Chandra, is that, to the best of their knowledge, no such standards, procedures as also processes ha....