Court Rules Personal Hearings Required for Legal Issues in Faceless Assessments; Revenue's 2020 Circular Deemed Unsustainable.

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....Violation of the scheme of faceless assessment u/s 144B - The argument of the respondent/Revenue that personal hearing would be allowed only in such cases which involve disputed questions of fact is untenable as cases involving issues of law would also require a personal hearing. This Court is of the view that the classification made by the respondents/Revenue by way of the Circular dated 23rd November, 2020 is not legally sustainable as the classification between fact and law is not founded on intelligible differentia and the said differentia has no rational relation to the object sought to be achieved by Section 144B of the Act. - HC....