Patna Smart City Limited Vs Assessment Unit (Patna High Court)
In the case of Patna Smart City Limited Vs Assessment Unit (Patna High Court), the petitioner, a government company funded by the government, challenged certain assessment orders issued under the Income Tax Act, 1961. The petitioner argued that the scrutiny was conducted contrary to the guidelines issued by the Central Board of Direct Taxes (CBDT) for the financial year 2021-22. The court, however, ruled that the CBDT guidelines for compulsory scrutiny did not prevent the random selection of cases by the Assessing Officers (AOs). The guidelines were designed for mandatory scrutiny categories, and they did not restrict other cases from being scrutinized. Additionally, the petitioner claimed a violation of natural justice due to the absence of a personal hearing. The court found that while the petitioner did not request a personal hearing explicitly in the application, the system allowed such a request. Since no personal hearing was sought, the court determined there was no violation of natural justice. Consequently, the court dismissed the writ petition, noting that the petitioner could file an appeal if desired, subject to exceptions including the limitation period.
FULL TEXT OF THE JUDGMENT/ORDER OF PATNA HIGH COURT
