A. Jaipal Reddy Amireddy v. UOI (2025) 478 ITR 509 (Telengana)(HC)

S. 147 :Reassessment-Faceless Assessment-Natural justice-Matter remanded to Assessing Officer to proceed in accordance with law.[S. 144C, 147, Art. 226]

On writ the Court held that the  duration to comply the notice was too short a period, particularly, when the explanation and details had been sought of an assessment year about seven to eight years old. Thereafter, by notice dated March 21, 2022 the period had been extended by another two days. There was no proof whether or not these notices issued on March 21, 2022 extending the period from March 21, 2022 to March 23, 2022 had been effectively served upon the assessee. Meanwhile the assessee had sent his reply on March 19, 2022 before the authority concerned. Proceedings had been drawn by the Department in a hasty manner without a reasonable opportunity of being heard given to the assessee. Therefore the order under section 147 read with section 144B was quashed and set aside. The matter was remitted to the Assessing Officer for proceeding in accordance with law after affording an opportunity of hearing to the assessee without any further delay.(AY. 2014-15)

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