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TMI Blog2023 (4) TMI 1225X X X X Extracts X X X X X X X X Extracts X X X X ..... the notice u/s 142(2) and partial response to notice u/s 142(1) and in the face of period of limitation for completion of proceeding coming to an end in the near future, the Revenue by notice afforded two days time to the petitioner/assessee for making his submission. Thus it is obvious that since all proceedings were conducted faceless including passing of orders, the contention of petitioner ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... FOR THE RESPONDENTS : SHRI SANJAY LAL ADVOCATE ORDER This petition filed u/Art. 226 of the Constitution assails order of assessment dated 29.04.2021 passed by the Income Tax Department under the provisions of Section 143(3) read with Section 144 B of Income Tax Act (IT Act for brevity) qua assessment year 2018-19 vide Annexure-P/1. 2. Pertinently, this Court while taking cogn ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Constitution of India. 5. The facts of the case reveal that petitioner who is a Govt. Company and which was earlier known as M.P. Trade Investment Facilitation Corporation Ltd. was selected for scrutinee by JAO as per instructions of CBDT dated 05.09.2019 pertaining to assessment year 2018-19. The Revenue followed the process laid down in Section 144-B of IT Act. Accordingly, notice under ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion pertaining to the huge expenditure claimed by the assessee. The assessee responded on 14.04.2021 by though submitting profit and loss account and copy of balance sheet, but without the schedule and supporting documents. Further, assessee failed to furnish any documentary evidence as regards the expenditure debited in profit and loss account. 6. In view of delayed compliance made by petitio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ernet facility, which is not the case herein. 8. In view of above it prima facie appears that there is no denial of reasonable opportunity of being heard while conducting the faceless assessment by Revenue. 9. Consequently, the petitioner is relegated to avail statutory remedy of appeal against the order of assessment in accordance with law. 10. With the aforesaid liberty, the present pet ..... X X X X Extracts X X X X X X X X Extracts X X X X
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