2024 (10) TMI 1372

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....Learned advocates appeared in the case: For the Petitioner : Mr. S. Ray, Senior Advocate Mr. K.K. Sahoo, Advocate Mr. D.K. Samal, Advocate For the opposite parties : Mr. S.C. Mohanty, Advocate (Senior Standing Counsel) ARINDAM SINHA, J. 1. Mr. Ray, learned senior advocate appears on behalf of petitioner and submits, impugned are assessment order dated 31st July, 2024 pertaining to asse....

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....otification dated 29th March, 2022. The notification says, it was made in exercise of powers conferred by sub-sections (1) and (2) of section 151-A. The section provides for faceless assessment of income escaping assessment. Accordingly, scope of the scheme, under section 3 thereof is, inter alia, assessment, reassessment or re-computation under section 147. We find from assessment order dated 31s....

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.... jurisdictional ITO, Sambalpur or if possible through Video Conferring. The assessee is ready to pay the cost of transportation and other expenses of the concerned persons to be cross examined." No opportunity of cross-examination was given in making of impugned assessment order. 5. On query from Court Mr. Ray refers us to impugned assessment order. He demonstrates, there was reliance on phy....

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.... 143 (3) read with section 260. Sub-section (1) in section 144-B (1), without the clauses thereunder is reproduced below. "144-B. Faceless assessment.-(1) Notwithstanding anything to the contrary contained in any other provisions of this Act, the assessment under sub-section (3) of section 143 or under section 144, in the cases referred to in sub-section (2), shall be made in a faceless m....