Satia Industries Limited v. National Faceless Assessment Centre (2021) 437 ITR 126 (Delhi)(HC)

S. 144B : Faceless Assessment-Natural justice-Draft assessment order-Variation in income-Personal hearing. [S. 144B(7)(vii), 156, 270A, Art. 226]

Allowing the petition the Court held no personal hearing was granted, despite a request being made to explain as the matter was complex. The court set aside the assessment order and the consequential notices issued under section 156 towards tax demand and under section 270A for initiation of penalty proceedings and gave liberty to the Department to proceed from the stage of issuing a notice-cum-draft assessment order with directions to afford an opportunity of hearing to the assessee.