JUDGMENT

Manmohan, J. (Oral)--The petition has been heard by way of video conferencing.

2. Present writ petition has been filed challenging the Assessment Order dated 24th May 2021 passed by the Respondent No.1 under section 143(3) read with section 144B for Assessment Year [AY] 2018-19, notice of demand issued under section 156 as well as notice for initiation of penalty proceeding under section 270A of the Act and all proceedings initiated pursuant thereto.

3. Learned senior counsel for the Petitioner states that the Respondent No.1 issued show cause notice requiring the Petitioner to show-cause by 23:59 hours on 25th April 2021 as to why assessment should not be completed as per draft assessment order. He further states that considering that the issues were numerous and factual, the Petitioner in response to the show-cause notice-cum-draft assessment order, made specific request for personal hearing under the specific tab/column `VC' in terms of Section 144B(7)(vii)-(ix) of the Act on the e-filing portal to make oral submissions providing necessary explanation and clarifications which was neither granted, nor rejected by Respondent No. 1.

4. He points out that the Responde