TMI Blog2024 (12) TMI 1485X X X X Extracts X X X X X X X X Extracts X X X X ..... been carried out, as per the guidelines issued by the Central Board of Direct Taxes and petitioner is a completely owned government company depending only on the government funds to carry out the development activities with its seat at Patna; totally funded by the Government - HELD THAT:- The guidelines, as placed is one for compulsory selection for returns of complete scrutiny during the financia ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is that the reply filed specifically sought for such personal hearing. As per the system generated notices and uploading of on-line replies in specified forms; there is a specific column provided for requesting personal hearing. Unless the personal hearing is sought for, there would be no requirement to issue such personal hearing. Admittedly, in the present case, the column for personal hearing ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... raised by the petitioner is that no scrutiny could have been carried out, as per the guidelines issued by the Central Board of Direct Taxes, as produced at Annexure-P/9 dated 10.06.2021. It is also submitted that the petitioner is a completely owned government company depending only on the government funds to carry out the development activities with its seat at Patna; totally funded by the Govern ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... far as no hearing having been granted to the assessee. Admittedly, the petitioner while uploading the application did not seek for an opportunity for personal hearing. The petitioner s contention is that the reply filed specifically sought for such personal hearing. As per the system generated notices and uploading of on-line replies in specified forms; there is a specific column provided for requ ..... X X X X Extracts X X X X X X X X Extracts X X X X
|