9911796707
TMI Blog2025 (2) TMI 91X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 (1) is for purpose of making the assessment. There is no dispute that petitioner's return was picked up for scrutiny assessment. The assessment had to be done. Commencement of the exercise of assessment was by issuance of section 143 (2) and then further enquiry felt necessary for purpose of the assessment and therefore second notice under section 142 (1). Petitioner having complied with both notices, the allegation of not having had full opportunity, particularly in view of statements made in the counter, are without basis. As the return filed was picked up for scrutiny assessment. Procedure provided for in section 144B on faceless assessment was adopted. It not being a case of best judgment assessment there was no draft assessment ord ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ld not have been resorted to following notice issued under section 143 (2), on its return filed. Furthermore, in doing the assessment, section 144B was also resorted to. As such by notification dated 17th February, 2021, substituted sub-paragraph (1) in paragraph 5 of the scheme of Faceless Assessment Scheme, 2019 required furnishing copy of draft assessment before the assessment was finalized. It cannot be disputed that draft assessment was not made available to his client. Mr. Patnaik submits still further, there has been violation of principles of natural justice inasmuch as sufficient opportunity was not given to his client. He seeks interference. 3. Mr. Kedia, learned advocate, Junior Standing Counsel appears on behalf of revenue and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Commencement of the exercise of assessment was by issuance of section 143 (2) and then further enquiry felt necessary for purpose of the assessment and therefore second notice under section 142 (1). Petitioner having complied with both notices, the allegation of not having had full opportunity, particularly in view of statements made in the counter, are without basis. 5. As aforesaid, facts in the case are that the return filed was picked up for scrutiny assessment. Procedure provided for in section 144B on faceless assessment was adopted. It not being a case of best judgment assessment there was no draft assessment order made and thus no question of furnishing it to the National e-Assessment Centre arose. 6. We have not been able to find ..... X X X X Extracts X X X X X X X X Extracts X X X X
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