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2025 Supreme(Del) 136

IN THE HIGH COURT OF DELHI AT NEW DELHI
Vibhu Bakhru, Tejas Karia
Marvy Outsourcing Private Limited – Appellant
Versus
National Faceless Assessment Centre Delhi – Respondent


Advocates Appeared:
For The Petitioner:Mr. Mani Bhadra Jain, Mr. Sachin Jain, Advocates.
For the Respondent:Mr. Shlok Chandra, Ms. Naincy Jain, Ms. Madhvi Shukla, Advocates.

ORDER :

1. The petitioner has filed the present petition, inter alia, impugning an assessment order dated 18.02.2025 [impugned order] passed under Section 143(3) read with Section 144B of the Income Tax Act, 1961 [the Act] as well as the consequential proceedings including issuance of notice of demand under Section 156 of the Act and initiation of penalty proceedings under Section 270A of the Act for the Assessment Year [AY] 2023-24.

2. The petitioner assails the impugned order on two grounds. First, that it has been passed in violation of the principles of the natural justice. And second, that the impugned order is ex facie erroneous and the reasoning of the Assessing Officer [AO] is perverse.

3. Insofar as the contention that the impugned order has been passed in violation of the principles of natural justice, the learned counsel appearing for the Revenue fairly concedes to the same.

4. In the present case, the show cause notice was issued on 02.12.2024 and the petitioner was called upon to respond by 08.12.2024. Subsequently, by an intimation letter dated 02.02.2025, the petitioner was granted a personal hearing on 03.02.2025 at 4:15 PM. The petitioner has produced the physical prin

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