9911796707
TMI Blog2024 (10) TMI 1372X X X X Extracts X X X X X X X X Extracts X X X X ..... (1) and (2) of section 151-A. The section provides for faceless assessment of income escaping assessment. Accordingly, scope of the scheme, under section 3 thereof is, inter alia, assessment, reassessment or re-computation under section 147. We find from assessment order dated 31st July, 2024, it was made under section 143 (3) read with section 260, pertaining to assessment year, 2021-22. The scheme has no application to the assessment. Violation of principles of natural justice - Section 144-B appears to be a complete code providing for faceless assessment. We have already noted before that impugned assessment order was made under section 143 (3) read with section 260. Sub-section (1) in section 144-B (1), without the clauses thereunder. I ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce on strength of notification dated 29th March, 2022. The notification says, it was made in exercise of powers conferred by sub-sections (1) and (2) of section 151-A. The section provides for faceless assessment of income escaping assessment. Accordingly, scope of the scheme, under section 3 thereof is, inter alia, assessment, reassessment or re-computation under section 147. We find from assessment order dated 31st July, 2024, it was made under section 143 (3) read with section 260, pertaining to assessment year, 2021-22. The scheme has no application to the assessment. 4. Mr. Ray submits, he has another point of challenge. It is violation of principles of natural justice. He draws attention to his client s reply dated 19th July, 2023 to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ars to be a complete code providing for faceless assessment. We have already noted before that impugned assessment order was made under section 143 (3) read with section 260. Sub-section (1) in section 144-B (1), without the clauses thereunder is reproduced below. 144-B. Faceless assessment.-(1 ) Notwithstanding anything to the contrary contained in any other provisions of this Act, the assessment under sub-section (3) of section 143 or under section 144, in the cases referred to in sub-section (2), shall be made in a faceless manner as per the following procedure, namely:- ... ... ... ... (emphasis supplied) Sub-section (2) in section 144-B is also reproduced below. (2) The faceless assessment under sub-section (1) shall be made in respect ..... X X X X Extracts X X X X X X X X Extracts X X X X
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