Held, that as the opportunity to respond to the show-cause notice was not made available to the assessee particularly, when the huge variation was proposed to be made which was prejudicial to the interest of the assessee, it violated the principles of natural justice. The order dated September 29, 2022 passed under section 143(3) read with section 144B was not valid. Order is set aside.(AY.2020-21)
Sun Glory Education Foundation v. NFAC(2023)457 ITR 771/156 taxmann.com 390 (Guj)(HC)
S. 144B : Faceless Assessment-Principle of natural justice-Must be given an opportunity of being heard. [S. 143(3),144B(1)(xi))(b), 144B(9), Art. 226]