Faceless assessment safeguards require prior inquiry, reasoned consideration and meaningful personal hearings before adverse reassessment.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Faceless assessment procedure requires necessary enquiry, verification and collection of relevant information before issuing a show cause notice, with reasoned consideration of explanations and reconciliations. Blanket notices and additions that disregard disclosed Category III AIF redemption proceeds or explained unlisted-share sale proceeds, including reliance on unrequested purchaser-source details, demonstrate arbitrariness and non-application of mind. Effective personal hearing is also required: a same-day hearing notice and an unresolved video-conference failure deny natural justice. These defects vitiated the assessment, consequential demand and penalty notices, requiring fresh proceedings, a hearing on at least five working days' notice before any adverse order, and a speaking, reasoned order.....