Allowing the petition the Court held that the requirement of giving an assessee a reasonable opportunity of personal hearing was mandatory and that the classification made by the National E-Assessment Centre between matters involving disputed questions of fact and law by way of circular dated November 23, 2020 was not legally sustainable. Accordingly, the assessment order passed against the assessee under section 143(3) read with section 144B and the consequent notice of demand issued under section 156 and notices for initiating penalty proceedings were quashed and the matter was remanded back to the Assessing Officer to pass fresh assessment order. (AY. 2018-19)