2023 (3) TMI 1164

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....r. Adv. Mr. Avra Mazumdar Mr. Ramesh Patodiya Ms. Megha Agarwal. For the Respondents : Mr. Smarajit Roychowdhury ORDER T. S. Sivagnanam J. 1. This intra-Court appeal is directed against the order dated 30th January, 2023 passed in W.P.A. 1306 of 2023. In the said writ petition the appellant had challenged the assessment order dated 20th December, 2022 under Section 143(3) read with Sec....

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....t blush it may appear that the challenge is to the assessment order passed by the authority on the merits of the case. However, on a careful consideration of the entire facts and circumstances of the case, it is clear that the appellant has not questioned the merits of the assessment but the decision making process. The Standard Operating Procedure (SOP) under the Faceless Assessment framed under ....

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.... which is impugned in the writ petition, one gets an impression that it is in compliance with the SOP as it contains requisite sub-headings but however, on a closure reading of the assessment order it is found that the assessing officer has acted in a most perverse manner in passing the assessment order. We say so because the first 21 pages of the assessment order is a verbatim extract of the show....