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June 2024

Re-assessment — Faceless assessment — Validity — Condition precedent for faceless assessment — Adequate opportunity should be provided to assessee to be heard:

By K B Bhujle | Ritu Punjabi, Advocates
Reading Time 3 mins

19 Packirisamy Senthilkumar vs. GOI

[2024] 461 ITR 473 (Mad.)

A.Y. 2016-17

Date of order: 2nd June, 2023

Ss. 144B and 147 of ITA 1961

Re-assessment — Faceless assessment — Validity — Condition precedent for faceless assessment — Adequate opportunity should be provided to assessee to be heard:

The assessee, a non-resident Indian, has been resident of Singapore since 1996 and a regular taxpayer there. During the previous year relevant to the AY 2016-17, the assessee purchased immovable properties amounting to ₹90,00,000 for which TDS was deducted. The assessee had not filed his return of income.

The assessee received a clarification letter dated 10th February, 2023 calling upon the assessee to reply along with documentary evidence stating that a sum of ₹1,80,00,000 had escaped assessment for the AY 2016-17. The assessee submitted a detailed

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