Assessing Officer passed reassessment order under section 147 read with sections 144B and made huge additions.\u00a0 Assessee filed writ on ground that no notice was issued to assessee prior to passing of assessment order.\u00a0 Revenue contended that in PAN database no e-mail id was registered and it could not be ascertained whether assessee had registered her email id prior to reassessment proceedings or during reassessment proceedings. Allowing the petition the Court held that\u00a0 whether if e-mail ID was not available in portal, it should have been served physically upon assessee at least by courier or speed post and acknowledgment filed as was also mentioned in SOP issued by CBDT for assessment units under faceless assessment. Revenue was to be directed to strictly comply with SOP in all cases, not just restricted to faceless assessment proceedings so that assessee would get reasonable opportunity to make his case. Matter is\u00a0\u00a0 remanded for de novo consideration. (AY. 2014-15)<\/p>\n","protected":false},"excerpt":{"rendered":"
S. 144B : Faceless Assessment-Opportunity of hearing-No notice was issued-PAN database no e-mail id was registered-Notice should have been served physically upon assessee at least by courier or speed post and acknowledgment filed as was also mentioned in SOP issued by CBDT for assessment units under faceless assessment-Revenue was to be directed to strictly comply with SOP in all cases, not just restricted to faceless assessment proceedings Reassessment and notice is quashed and set aside-Matter remanded for de novo consideration.[S. 147, 148, Art. 226] <\/p>\n","protected":false},"author":3,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_acf_changed":false,"jetpack_post_was_ever_published":false,"_jetpack_newsletter_access":"","_jetpack_dont_email_post_to_subs":false,"_jetpack_newsletter_tier_id":0,"_jetpack_memberships_contains_paywalled_content":false,"_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[21],"tags":[],"class_list":["post-43021","post","type-post","status-publish","format-standard","hentry","category-income-tax-act"],"acf":[],"jetpack_featured_media_url":"","jetpack_shortlink":"https:\/\/wp.me\/p9S2Rw-bbT","jetpack-related-posts":[],"jetpack_sharing_enabled":true,"_links":{"self":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43021","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/users\/3"}],"replies":[{"embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/comments?post=43021"}],"version-history":[{"count":1,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43021\/revisions"}],"predecessor-version":[{"id":43022,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/posts\/43021\/revisions\/43022"}],"wp:attachment":[{"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/media?parent=43021"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/categories?post=43021"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/itatonline.org\/digest\/wp-json\/wp\/v2\/tags?post=43021"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}