Court held that an assessee had a vested right to personal hearing and it ought to have been given, if the assessee had asked for it. No opportunity of personal hearing was given despite a specific request made by the assessee. The right to personal hearing could not depend upon the facts of each case. Despite “nil” variation proposed in the notice, additions had been made to the assessed income in the draft assessment order and the final assessment order. No notice, as mandatorily required by section 144B(1)(xvi), had been served upon the assessee with respect to the variations made in the income. The draft assessment order had also been issued without considering the reply which was submitted by the assessee in time in response to the notice issued under section 142(1). The classification made by the Department by way of the Circular dated November 23, 2020 issued by the Central Board of Direct Taxes was not founded on intelligible differentia and the differentia had no rational relation to the object of section 144B. The final assessment order and the notice of demand were set aside and the matter was remanded back to the Assessing Officer to issue notice and a draft assessment order and thereafter pass a reasoned order in accordance with law. Matter remanded. Relied on  Raghunath Thakur v. State of Bihar [1989] 1 SCC 229,Gautam (C. B.) v. UOI (1993) 199 ITR 530(SC) and Sahara India (Firm) v. CIT (2008) 300 ITR 403 (SC). The word may in section 144B(7)(viii) should be read as must or shall and requirement of giving an assessee a reasonable opportunity of personal hearing is mandatory. (AY.2018-19)