Allowing the petition the Court held that there could not be a hyper technical approach, especially with the assessee placing on record the response at 11 :50 a.m., which was not contradicted. The decision on the assessee’s objections to the reassessment proceedings under section 147, the assessment order and consequential demand notices were quashed. The Assessing Officer was directed to afford another opportunity of hearing in compliance with the Faceless Assessment Scheme parameters.(AY.2014-15)
Harsha Bhavesh Patel (Smt.) v NFAC (2023)456 ITR 476 (Karn)(HC)
S. 147 : Reassessment-Faceless Assessment-Principle of natural justice-Oder passed without giving an opportunity of hearing–Reassessment proceedings and consequential notices quashed-Assessing Officer is directed to afford due opportunity and pass order accordingly. [S. 148, 156, Art. 226]