Held, that the assessee did not get proper opportunity to explain his case before the authorities and since the Assessing Officer had completed the assessment under section 144, the issue was restored to the file of the Assessing Officer for re-adjudication after affording due and reasonable opportunity of being heard to the assessee.(AY. 2009-10)
Gopi Kishan Pandey v.ITO (2022) 99 ITR 203 (Trib) (Lucknow)(Trib)
S. 147 : Reassessment-Best Judgment Assessment-Natural justice-Notice issued u/s 143(2)-Assessee was out of station-Not attended-Order was passed under section 144-Matter remanded for re-adjudication. [S.50C, 143(2),144, 148]