2022 (3) TMI 781

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....Mr. Amol Sinha & Mr. Ashvini Kumar, Advs. Respondents Through: Mr. Kunal Sharma, Sr. SC with Ms. Zehra Khan, Jr. SC and Mr. Shubhendu Bhattacharyya, Adv J U D G M E N T MANMOHAN, J (Oral) 1. Present writ petition has been filed challenging the impugned assessment order dated 22nd April, 2021 passed under Section 143(3) read with Section 144B of the Income Tax Act, 1961 for the assessme....

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....ass the impugned assessment order dated 22nd April, 2021 under Sections 143(3) and 144B of the Act by making an addition of Rs. 4,95,52,897/- against the returned income of Rs. 6,82,06,650/- resulting into total assessed income of Rs. 11,77,59,547/- and the consequential notice of demand, and the Respondents further issued a notice for initiating penalty proceedings. 4. Learned counsel for the ....

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....al hearing is mandatory. It was further held that the classification made by the Respondent between the matters involving disputed questions of fact and law by way of the Circular dated 23rd November, 2020 is not legally sustainable. 6. Accordingly, the impugned assessment order dated 22nd April, 2021 passed under Sections 143(3) and 144B of the Income Tax Act, 1961 as well as notices for deman....