Vellaian Selvaraj v. ACIT (2022) 441 ITR 644/ 213 DTR 309 / 326 CTR 550 (Mad.)(HC) Kumaravel Muthiah Mallika v. ACIT (2022) 441 ITR 644 / 213 DTR 309 (Mad.) (HC)

S. 144B : Faceless Assessment-Natural justice-Merely reproducing content of assessees replies to notices is not sufficient-Matter remanded for passing order. [Art. 226]

The Assessing Officer passed the order by merely reproducing the replies of the assessees to the notices with one addition simply stating that the replies of the assessees were not satisfactory.    On writ the Court held that the assessment orders merely reproduced the content of the replies of the assessees to the notices, and there was no discussion to support the conclusion in the assessment orders. Only a conclusion had been given in the assessment orders that the replies filed by the assessees to the notices were not satisfactory. This was not sufficient. The orders passed were non-speaking orders and therefore were quashed and the matter was remanded for fresh consideration and to pass speaking order. (AY.2019-20)