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