JUDGMENT :

MANMOHAN, J.

1. Present writ petition has been filed challenging the impugned assessment order dated 26th May, 2021 passed by the respondent under Section 143(2) of the Income Tax Act, 1961 [‘the Act’].

2. Learned counsel for the Petitioner states that the principal grievance of the petitioner is that the impugned assessment order for the assessment year 2018-19, was passed in violation of Section 144B(7)(vii) of the Act.

3. He points out that the petitioner had sought personal hearing on two dates, i.e., 30th March, 2021 and 19th April, 2021. He emphasises that a request for oral hearing was made on 19th April, 2021 by way of the petitioner's reply/objection to the show cause notice and draft assessment order dated 15th April, 2021.

4. He states that even though the petitioner's declared income was Rs. 7,30,700/- the Respondent/revenue had enhanced the declared income to Rs. 46,02,60,330/- thereby proposing disallowances/additions amounting to Rs. 45,95,29,630/- against the Petitioner.

5. He also points out that the demand raised against the petitioner, as indicated in the notice issued under Section 156 of the Act, dated 26th May, 2021, is Rs. 49,68,78,182/-.

6. Per contra, M