“1. Total income Returned,"Rs. 29,66,880/-
2. Addition (As discussed in para 9.2 )
(Interest received on enhanced compensation)
(rounded off)","Rs. 14,68,57,790/-
Less: Deduction @50%,"Rs 7,34,28,895/-
iii) Total assessed income,"Rs.7,63,95,775/-â€
4.2. This being the position, clearly, the provisions of Section 144B(7)(vii) of the Act would apply in this case.",
4.3. We may note that this issue has received consideration of this Court, inter alia, in judgment dated 27.05.2021, passed in WP(C) No.5537/2021,",
titled Ritnand Balved Education Foundation (Umbrella Organization of Amity Group of Institutions) v. National Faceless Assessment Centre & Ors.,
The relevant observations made in the said judgment are extracted hereafter:,
 "" 7.1. For the sake of convenience, the relevant part of Section 144B(7)(vii) of the Act and the SOP framed by the CBDT are extracted hereafter:",
 “144B. Faceless assessment -,
 xxx xxx xxx,
 (7) For the purposes of faceless assessmentâ€",
 xxx xxx xxx,
 (vii) in a case where a variation is proposed in the draft assessment order or final draft assessment order or revised draft assessment order, and an",
opportunity is provided to the assessee by serving a notice calling upon him to show cause as to why the assessment should not be completed as per,
the such draft or final draft or revised draft assessment order, the assessee or his authorised representative, as the case may be, may request for",
personal hearing so as to make his oral submissions or present his case before the income-tax authority in any unit;,
 xxx xxx xxx†“STANDARD OPERATING PROCEDURE (SOP) FOR PERSONAL HEARING THROUGH VIDEO CONFERENCE,
UNDER THE FACELESS ASSESSMENT SCHEME, 2019",
 CIRCULAR F. NO. PR. CCIT/NeAC/SOP/2020-21, DATED 23-11-2020",
 The Principal Chief Commissioner of Income Tax, National e-assessment Centre, with the prior approval of the Central Board of Direct Taxes,",
New Delhi, lays down the following circumstances in which personal hearing through Video Conference shall be allowed in the Faceless Assessment",
Scheme, 2019:",
 Where any modification is proposed in the draft assessment order (DAO) issued by any AU and the Assessee or the authorized representative in,
his/her written response disputes the facts underlying the proposed modification and makes a request for a personal hearing, the CCIT ReAC may",
allow personal hearing through Video Conference,after considering the facts & circumstances of the case, as below:-",
 1. The Assessee has submitted written submission in response to the DAO.,
 2. The Video Conference will ordinarily be of 30 minutes duration. That may be extended on the request of the Assessee or authorised,
representative.,
 3. The Assessee may furnish documents/evidence, to substantiate points raised in the Video Conference during the session or within a reasonable",
time allowed by the AU, after considering the facts and circumstances of the case.â€",
 7.2. As would be evident, this provision [i.e., Section 144B(7)(vii) of the Act] would squarely apply in this case, as a specific request for personal",
hearing was made on behalf of the petitioner. The request made by the petitioner is contained in its communication dated 23.04.2021, appended on",
page 324 of the paper book [See Annexure P-29 (Colly)].,
 7.3. We may also note that, in the Lemon Tree Case, we had queried Ms. Malhotra as to whether any standards, procedures and processes have",
been framed by revenue in terms of sub-clause (h) of clause (xii) of Section 144B(7) of the Act . Ms. Malhotra had informed us that, in this regard,",
she had no instructions. We have queried Ms. Malhotra, once again today. Ms. Malhotra says that she has, still, not received any instructions in that",
regard.,
144B.,
xxx xxx xxx,
(xii) the Principal Chief Commissioner or the Principal Director General, in charge of the National Faceless Assessment Centre shall, with the prior",
approval of the Board, lay down the standards, procedures and processes for effective functioning of the National Faceless Assessment Centre,",
Regional Faceless Assessment Centres and the unit set up, in an automated and mechanised environment, including format, mode, procedure and",
processes in respect of the following, namely:â€"",
(h) circumstances in which personal hearing referred to clause (viii) shall be approved;,
 7.4. Therefore, we have to presume that, no standards, procedures and processes have been framed in terms of clause (xii) Section 144B(7) of the",
Act. These standards, procedures and processes are required to be framed, to guide the assessing officer as to whether or not personal hearing in a",
given matter should be granted.,
 7.5. That apart, in our view, since the statute itself makes the provision for grant of personal hearing, the respondents/revenue cannot veer away",
from the same.""",
5. Accordingly, in view of the aforesaid discussion, the prayer made in the writ petition is allowed.",
5.1. The impugned assessment order dated 07.06.2021, as well as consequential notices i.e., the notice of demand issued under Section 156 of the Act,",
and the notice issued for initiation of penalty proceedings under Section 270A of the Act, of even date, are set aside.",
5.2. Needless to add, if the AO is desirous to proceed further in the matter, she/he will have the liberty to do so, albeit as per law.",
6. The writ petition is, accordingly, disposed of. Pending application(s), if any, shall stand closed.",
