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2023 (4) TMI 1225 - MADHYA PRADESH HIGH COURTValidity of faceless assessment u/s 144B - denial of reasonable opportunity of being heard while conducting the faceless assessment - HELD THAT:- In view of delayed compliance made by petitioner/assessee, response to 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 of denial of opportunity of physical hearing cannot be countenanced. Moreso, the ground of disabling factor of close down imposed due to Covid 19 pandemic also cannot be treated as good ground. The online proceedings of faceless assessment could have been undertaken even during lock down, unless there was a break down of internet facility, which is not the case herein. There is no denial of reasonable opportunity of being heard while conducting the faceless assessment by Revenue. Petitioner is relegated to avail statutory remedy of appeal against the order of assessment in accordance with law.
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