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TMI Blog2023 (3) TMI 1164X X X X Extracts X X X X X X X X Extracts X X X X ..... a cursory perusal of the assessment order one gets an impression that it is in compliance with the SOP as it contains requisite sub-headings but however, on a closure reading of the assessment order it is found that the AO has acted in a most perverse manner in passing the assessment order. First 21 pages of the assessment order is a verbatim extract of the show cause notice. In page nos.22 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... For the Respondents : Mr. Smarajit Roychowdhury ORDER T. S. Sivagnanam J. 1. This intra-Court appeal is directed against the order dated 30th January, 2023 passed in W.P.A. 1306 of 2023. In the said writ petition the appellant had challenged the assessment order dated 20th December, 2022 under Section 143(3) read with Section 144B of the Income Tax Act, 1961 (for brevity the Act ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t order passed by the authority on the merits of the case. However, on a careful consideration of the entire facts and circumstances of the case, it is clear that the appellant has not questioned the merits of the assessment but the decision making process. The Standard Operating Procedure (SOP) under the Faceless Assessment framed under Section 144B of the Act had been issued by the National Face ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion that it is in compliance with the SOP as it contains requisite sub-headings but however, on a closure reading of the assessment order it is found that the assessing officer has acted in a most perverse manner in passing the assessment order. We say so because the first 21 pages of the assessment order is a verbatim extract of the show cause notice. In page nos.22 and 23 in two paragraphs the r ..... X X X X Extracts X X X X X X X X Extracts X X X X
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