Allowing the petition the Court held that the order of assessment under section 153 read with section 144 of the Income-tax Act, 1961 had been passed by the Assessing Officer without giving the assessee an opportunity of being heard. The orders were set aside on the ground of not giving opportunity and resultant breach of principles of natural justice. The order was not valid. (AY. 2013-14 to 2019-20)
Manishkumar Tulsidas Kaneriya v. ACIT (2023)454 ITR 153 / 293 Taxman 127 (Guj)(HC)
S. 144 : Best judgment assessment-Order passed without giving an opportunity to be heard-Violation of principles of natural justice-Order is not valid [S. 142(1), 153, Art. 226]