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2023 (3) TMI 1164 - HC - Income TaxValidity of assessment order u/s 143(3) r.w.s.144B - as argued it is total violation of the principles of natural justice and it has ignored all the formalities to be observed as enumerated under the Standard Operating Procedure (SOP) for faceless assessment orders - HELD THAT:- On a cursory perusal of the assessment order one gets an impression that it is in compliance with the SOP as it contains requisite sub-headings but however, on a closure reading of the assessment order it is found that the AO has acted in a most perverse manner in passing the assessment order. First 21 pages of the assessment order is a verbatim extract of the show cause notice. In page nos.22 and 23 in two paragraphs the reply given by the assessee has been summarized. From page nos.23 to 36 of the assessment order it is once again extract of the show cause and ultimately at page nos.37 and 38 the total income has been determined and the assessment is completed. The impugned assessment order is a classical example as to how an assessment should not be made. AO has reduced the procedure to an empty formality, which has to be deprecated. This leaves us with no other option except to quash the assessment order.
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