Wtax/465/2022 Of Harish Chandra Bhati v. Principal Commissioner Of Income Tax Noida And 2 Others

Court No. - 03 Case :- WRIT TAX No. - 465 of 2022 Petitioner :- Harish Chandra BhatiRespondent :- Principal Commissioner Of Income Tax Noida And 2 OthersCounsel for Petitioner :- Ashish BansalCounsel for Respondent :- Gaurav Mahajan,Arvind Kumar Goswami Hon'ble Surya Prakash Kesarwani,J.Hon'ble Jayant Banerji,J. 1. Heard Sri Ashish Bansal, learned counsel for the petitioner, Sri S.P. Singh,learned Additional Solicitor General of India assisted by Sri Arvind KumarGoswami, learned Central Government Standing Counsel and Sri AshishAgarwal, learned Standing Counsel for the respondent-Income Tax Department. 2. A personal affidavit of respondent No.4, namely, Sri Tarun Bajaj, RevenueSecretary to the Government of India, New Delhi dated 19.5.2022 has been filedtoday which is taken on record. 3. Learned Additional Solicitor General has referred to paragraphs 9 and 10 ofthe aforesaid personal affidavit dated 19.5.2022 and stated that the date of circularin paragraph 10 has been wrongly mentioned as 25.4.2022 instead 23.4.2022 andcopy of said circular dated 23.4.2022 has already been filed alongwith thepersonal affidavit dated 3.5.2022. He further states that the Government’s standstated in paragraph 10 of the personal affidavit dated 19.5.2022 is clear and,accordingly, the Government shall take all actions against the erring officers. 4. In the order dated 30.03.2022 passed by this court, submissions of thelearned counsel for the petitioner have been noted as under:- “Learned counsel for the petitioner submits that the two land in question were jointlyowned by seven persons. The petitioner herein and the aforesaid Dushyant Bhati bothwere also co-owners of the aforesaid agricultural land which was sold by two separateregistered sale deeds. For the same set of reasons proceedings under Section 148 of theAct, 1961, were initiated against the petitioner and the aforesaid Dushyant Bhati who isthe son of the petitioner. The Assessment Order dated 23.03.2022 under Section 147read with Section 144 B of the Act, 1961, in respect of Dushyant Bhati has been passedby the National Faceless Assessment Centre, Delhi, accepting his claim that the land inquestion was accepted to be an agricultural land situate beyond 8 km. of municipal limits. Thus the disclosed income in the returns for the Assessment Year 2013-14has been accepted and no tax has been imposed in respect of the sale of the land inquestion. On the other hand totally contrary view has been taken in the matter of thepetitioner vide reassessment order dated 28.03.2022, under Section 147 read withSection 144 B of the Act, 1961, passed by the National Faceless Assessment Centre,Delhi, whereby 1/7th of the consideration in respect of the land in question,belonging to the petitioner, has been assessed as a long term capital gain on thefinding that the land in question is not an agricultural land. Thus, on the same set offacts while the respondents have accepted the claim of petitioner's son in respect ofthe same land and on the other hand in respect of the same land the stand taken bythe petitioner has been rejected and the sale proceeds of the agricultural land hasbeen assessed as a long term capital gain.” 5. In the order dated 18.04.2022, submission of learned counsel for therespondent Nos.1, 2 and 3 has been noted, as under: “Today, learned counsel for the respondent nos.1, 2 and 3 states that conflictingorders are being passed by National Faceless Assessment Centre and for whichsteps shall be taken to remove the anomalies. In view of the statement as aforenoted and also the fact that two conflictingreassessment orders have been passed by the National Faceless Assessment Centrein respect of two co-owners of the same land, we direct the newly impleadedrespondent no.4 to look into the matter and file his personal affidavit explaining thestate of affairs and the steps being taken by the Government.” 5. In the order dated 18.04.2022, submission of learned counsel for therespondent Nos.1, 2 and 3 has been noted, as under: “Today, learned counsel for the respondent nos.1, 2 and 3 states that conflictingorders are being passed by National Faceless Assessment Centre and for whichsteps shall be taken to remove the anomalies. In view of the statement as aforenoted and also the fact that two conflictingreassessment orders have been passed by the National Faceless Assessment Centrein respect of two co-owners of the same land, we direct the newly impleadedrespondent no.4 to look into the matter and file his personal affidavit explaining thestate of affairs and the steps being taken by the Government.” 6. In response, a personal affidavit dated 03.05.2019 on behalf of Union ofIndia has been filed by Sri Tarun Bajaj, Revenue Secretary to the Governmentof India who has stated in paragraph-11 of the affidavit, as under: “11. The petitioner has an alternate administrative remedy in form of approachingthe Local Committee for grievance settlement instead of approaching the Court inwrit proceedings. Local committee has been empowered to deal with Taxpayer'sGrievances from High-Pitched Scrutiny Assessment upon receipt of grievances,related to High-pitched Scrutiny assessments completed either under the FacelessAssessment regime or non-faceless Assessment regime and ascertain whether thereis a prima-facie case of High-pitched Assessment, non-observance of principles ofnatural justice, non-application of mind or gross negligence of AssessingOfficer/Assessment Unit. Issues such as the present case can be resolved byindividual taxpayers through the remedy of approaching local committees set up forgrievance redressal. [A True Copy of the Revised Instruction for dealing with Taxpayer's grievance fromHigh pitched scrutiny assessment, dated 23.04.22 (earlier version being InstructionNo 17/2015 dt. 09/11/2015) is marked as Annexure A]” 7. True copy ofinstructions/ Circular F.No.225/101/2021-ITA-II, Government of India, Ministry of Finance, Department of Revenue, CentralBoard of Direct Taxes dated 23.04.2022 issued under Section 119 of theIncome Tax Act, 1961 and filed as Annexure A-1 to the personal affidavitdated 03.05.2022 is reproduced below: To “F.No.225/101/2021-ITA-IIGovernment of IndiaMinistry of FinanceDepartment of RevenueCentral Board of Direct Taxes***************** Room No. 245-A, North Block,New Delhi, the 23[rd] April, 2022 All Pr. CCsIT/DGsIT/Pr.CCIT(Exemption)/Pr. CCIT(International-tax) Madam/Sir, Subject: Revised Instruction for constitution and functioning of ‘Local Committees todeal with Taxpayers’ Grievances from High-Pitched Scrutiny Assessment’ -reg. The Central Board of Direct Taxes (the 'CBDT'), by its Instruction No. 17/2015,dated 9-11-2015 (copy enclosed) provided for constitution of 'Local Committees to dealwith Taxpayers' Grievances from High-Pitched Scrutiny Assessment' in each Pr.CCITregion. The Local Committees were constituted to expeditiously deal with Taxpayers'grievances arising from High-Pitched Scrutiny Assessment. 2. Taking into consideration the changes in organizational set-up subsequent to launchof Faceless Assessment regime, the CBDT, in exercise of its powers under section 119of the Income-tax Act, 1961 ('the Act') and in supersession of its earlier Instruction No.17/2015 dated 9-11-2015, hereby issues the following instructions regardingconstitution and functioning of 'Local Committees to deal with Taxpayers' Grievancesfrom High-Pitched Scrutiny Assessment': A. Constitution of Local Committees: (i)Local Committees to deal with Taxpayers' Grievances from High-Pitched ScrutinyAssessment ('Local Committees') are required to be constituted in each Pr.CCIT regionacross the countryincluding the Pr.CCIT(Exemption) and Pr.CCIT(InternationalTaxation). 2. Taking into consideration the changes in organizational set-up subsequent to launchof Faceless Assessment regime, the CBDT, in exercise of its powers under section 119of the Income-tax Act, 1961 ('the Act') and in supersession of its earlier Instruction No.17/2015 dated 9-11-2015, hereby issues the following instructions regardingconstitution and functioning of 'Local Committees to deal with Taxpayers' Grievancesfrom High-Pitched Scrutiny Assessment': A. Constitution of Local Committees: (i)Local Committees to deal with Taxpayers' Grievances from High-Pitched ScrutinyAssessment ('Local Committees') are required to be constituted in each Pr.CCIT regionacross the countryincluding the Pr.CCIT(Exemption) and Pr.CCIT(InternationalTaxation). (a) The Local Committee shall consist of 3 members of Pr.CIT/CIT rank. Tohave a perspective of processes involved in Faceless Assessment process, LocalCommittees so constituted in each Pr. CCIT region and Pr.CCIT(Exemption)shall have one Pr.CIT (AU) of the region. The Local Committee constitutedunder the Pr.CCIT(International Taxation) need not have a Pr.CIT(AU) as a member, as the assessments under the International Taxation charges areoutside the purview of Faceless Assessment regime. (b) The other members may be selected from the pool of officers posted asPr.CsIT/Pr. CIT(Central)/CIT(Judicial)/ CIT(Audit)/CsIT(DR), ITAT of therespective Pr.CCIT region. For the Local Committees constituted under thePr.CCIT(Exemption) and Pr.CCIT(International Taxation), members may beselected from their respective pool of officers. (c) The senior most Member would be designated as the Chairperson of theCommittee. (d) The Addl. CIT (Headquarters) to such Pr. CCIT would act as a Member -Secretary to the Local Committee. (ii) The Local Committees so constituted may co-opt other members, if necessary. (iii)The Pr. CCIT concerned should ensure that the Local Committees are dulyreconstituted after transfer/promotion of Members of the existing Local Committees. (iv) Adequate publicity shall be given regarding constitution and functioning of LocalCommittees for filing of grievance petitions regarding High-Pitch ScrutinyAssessments. The communication address of such Local Committees shall be displayedat prominent places in the office building. B. Jurisdiction of Local Committees: The Local Committees constituted as above shall deal with the grievancepetitions of the assessees under the jurisdiction of respective Pr.CCIT regarding High-Pitched Scrutiny Assessments completed under both Faceless and non-FacelessAssessment regimes. These Committees constituted in Pr. CCIT Region will alsohandle the grievances pertaining to Central Charges located under the territorialjurisdiction of the Pr. CCIT concerned. C. Receipt of Grievances: (i)Grievances related to High-Pitched Scrutiny Assessments completed under theFaceless Assessment regime will be received by NaFAC through dedicated e-mail id: . Grievances so received shall beforwarded to Local Committee of the Pr. CCIT concerned by NaFAC, under intimationto Pr. CCIT of the Region/ Pr.CCIT(Exemption). (ii) Grievances related to High-Pitched Scrutiny Assessments completed under the non- Faceless Assessment regime will be received by the office of Pr.CCIT concerned,physically or through e-mail. Grievances so received shall be forwarded to LocalCommittee of the Pr. CCIT concerned. D. Action to be taken by the Local Committees on grievance petitions: (i) A grievance petition received by the Local Committee would be acknowledged. Aseparate record would be maintained for dealing with such petitions by the Member-Secretary. (ii)Member - Secretary on receipt of taxpayers' grievances of High-PitchedAssessment, will forward the same to the Chairman and Members of the LocalCommittee within three days of receipt of the grievance. (ii) Grievances related to High-Pitched Scrutiny Assessments completed under the non- Faceless Assessment regime will be received by the office of Pr.CCIT concerned,physically or through e-mail. Grievances so received shall be forwarded to LocalCommittee of the Pr. CCIT concerned. D. Action to be taken by the Local Committees on grievance petitions: (i) A grievance petition received by the Local Committee would be acknowledged. Aseparate record would be maintained for dealing with such petitions by the Member-Secretary. (ii)Member - Secretary on receipt of taxpayers' grievances of High-PitchedAssessment, will forward the same to the Chairman and Members of the LocalCommittee within three days of receipt of the grievance. (iii) The grievance petition received by Local Committee would be examined by it toascertain whether there is a prima facie case of High-Pitched Assessment, non-observance of principles of natural justice, non-application of mind or gross negligenceof Assessing Officer/Assessment Unit. (iv) The Local Committee may call for the relevant assessment records to peruse fromthe Jurisdictional Pr.CIT concerned. (vi) The Local Committee may seek inputs from the Directorate of Systems (ITBA/e-filing/CPC-ITR, CPC-TDS, etc.), on Systems-related issues emanating from thegrievance/matter under consideration, if considered necessary. (vii)Local Committee would ascertain whether the addition(s) made in assessmentorder is/are not backed by any sound reason or logic, the provisions of law have grosslybeen misinterpreted or obvious and well-established facts on records have outrightlybeen ignored. The Committee would also take into consideration whether principles ofnatural justice have been followed by the Assessing Officer/Assessment Unit.Thereafter, Local Committee shall submit a report treating the order asHigh-Pitched/Not High-pitched, along with the reasons, to the Pr. CCIT concerned. (viii)The Local Committee shall endeavor to dispose of each grievance petition withintwo months from the end of the month in which such petition is received by it. (ix) Member-Secretary will ensure that the meetings of the Local Committees are heldat least twice in every month during the pendency of the grievance petitions and thattimely reports are submitted to the Pr. CCIT concerned. E. Follow up action by Pr.CCIT: (i) On receipt of the report of Local Committee, Pr. CCIT concerned may take suitableadministrative action in respect of cases where assessment was found to be High-Pitched by the Local Committee, which inter alia include: (a)Calling for explanation of the Assessing Officer/Assessment Unit (through Pr.CCIT, NaFAC) and any other administrative action as deemed fit. (b)Administratively advise the Pr.CIT concerned to prevent any coerciverecovery in cases identified as high pitched by the Local Committee.recovery in cases identified as high pitched by the Local Committee. (ii)The findings of the report of the Local Committee may also be shared by thePr.CCIT concerned with NaFAC and/or Directorate of Income-tax(Systems), asfeedback, for revisiting the SOP/policy on Faceless Assessment and/or addressing theSystems related issues. F. Monitoring the functioning of Local Committee: (i) The Pr. CCIT concerned shall review the work of the Local Committee on a monthlybasis. Pr. CCsIT shall highlight outcome of work of Local Committees along with theaction taken on the suggestions made by the Local Committees in respect of caseswhere assessment were found to be High-Pitched by the Local Committees, in theirmonthly D.O. letters to the respective Zonal Member. (ii) Quarterly Report regarding the functioning of Local Committees shall be furnishedby the Pr. CCIT concerned to the O/o Member (IT&R), CBDT under intimation to therespective Zonal Member in the prescribed format (copy enclosed) by 15th of themonth following the quarter ended. F. Monitoring the functioning of Local Committee: (i) The Pr. CCIT concerned shall review the work of the Local Committee on a monthlybasis. Pr. CCsIT shall highlight outcome of work of Local Committees along with theaction taken on the suggestions made by the Local Committees in respect of caseswhere assessment were found to be High-Pitched by the Local Committees, in theirmonthly D.O. letters to the respective Zonal Member. (ii) Quarterly Report regarding the functioning of Local Committees shall be furnishedby the Pr. CCIT concerned to the O/o Member (IT&R), CBDT under intimation to therespective Zonal Member in the prescribed format (copy enclosed) by 15th of themonth following the quarter ended. 3. The purpose of constitution of Local Committees is to effectively and efficiently dealwith the genuine grievances of taxpayers and help in supporting an environment whereassessment orders are passed in a fair and reasonable manner. It is to be noted thatLocal Committees cannot be treated as an alternative forum to disputeresolution/appellate proceedings. 4. It is emphasized that the task of constitution of Local Committees as per thisInstruction be finalized within 15 days of issue of this Instruction or 30-4-2022,whichever is later, and compliance report may be sent by the Jurisdictional Pr.CCsIT/Pr. CCIT (Intl.Tax.)/ Pr.CCIT(Exemptions) to their respective Zonal Memberswith a copy to Member (IT&R), CBDT. 5. This issues with the approval of Chairman, CBDT. Enclosure: As above (Ravinder Maini) (Director)(ITA-II), CBDT. Copy to: 1) The Chairperson, CBDT and all Members, CBDT 2) PS to the Secretary (Revenue) 3) All JS/CsIT, CBDT 4) ITCC division, CBDT 5) Jt. CIT, Data base Cell for uploading on the Department Website:www.irsofficersonline.gov.in 6) O/o Pr. DGIT (Systems) for uploading on Official Website: www.incometax.gov.in 7) CIT (Media Coordinator), CBDT 8) Guard file (Ravinder Maini) (Director)(ITA-II), CBDT. Annexure: Quarterly Report on functioning of Local Committees to deal with taxpayers’-grievances from HighPitched Scrutiny Assessments Date: Quarter 1/2/3/4, Year____ (Note: The above information is to be submitted by 15[th] of the month following thequarter ended)” 8. On 05.05.2022, this Court passed the following order: “Sri S.P. Singh, learned Additional Solicitor General has filed a personal affidavitdated 03.05.2022 of Sri Tarun Bajaj, Revenue Secretary to the Government of Indiaannexing therewith a circular dated 23.04.2022 providing for constitution of localcommittees which prima facie appears to be wholly unsatisfactory and a completeeyewash to address the problem being faced by assessees on account of conflictingorders by the National Faceless Assessment Centre, New Delhi inasmuch as itmerely provides a forum for complaint without any relief to the complainant andwithout fixing of accountability of the erring officers. It is highly improbable thatan assessee shall make complaint against his assessing officer whether faceless ornon-faceless without any relief to him from arbitrary assessment order or orderpassed in breach of principles of natural justice. Learned Additional Solicitor General states that the Revenue Secretary to theGovernment of India shall file a better affidavit indicating solution to the problemof conflicting orders, arbitrary orders and frequent breach of principles of naturaljustice by assessing authorities including National Faceless Assessment Centre,within two weeks. Time as prayed is granted. Put up as a fresh case on 19.05.2022 for further hearing.” 9. In the personal affidavit filed today, the respondent No.4 by means ofpersonal affidavit of Sri Tarun Bajaj, Revenue Secretary to the Government ofIndia, New Delhi has stated in paragraphs-10 and 12, as under:- Learned Additional Solicitor General states that the Revenue Secretary to theGovernment of India shall file a better affidavit indicating solution to the problemof conflicting orders, arbitrary orders and frequent breach of principles of naturaljustice by assessing authorities including National Faceless Assessment Centre,within two weeks. Time as prayed is granted. Put up as a fresh case on 19.05.2022 for further hearing.” 9. In the personal affidavit filed today, the respondent No.4 by means ofpersonal affidavit of Sri Tarun Bajaj, Revenue Secretary to the Government ofIndia, New Delhi has stated in paragraphs-10 and 12, as under:- “10. It is further respectfully submitted that even though a large number ofassessments were carried out efficiently and effectively, yet, recognising thedifficulties faced by the tax payers, the Central Board of Direct Taxes issuedinstruction F. No. 225/101/2021/-ITA-II, dt. 25/04/22, for dealing with taxpayersgrievances. The local committee ascertains whether the additions made in theassessment order is not backed by any sound reasons or logic, provisions of lawhave been grossly misinterpreted or obvious and well-established facts on recordhave been ignored outrightly. The said instruction also provides for initiation ofsuitable administrative action against the erring officer in case where assessmentsare found by the local committee to be high-pitched or where there is non-observance of principles of natural justice, non- application of mind or grossnegligence of assessing officer/ Assessment Unit. Also, the findings of the localcommittee are considered for revisiting SOP/policy on faceless assessment andaddressing systems related issues. 12. The Petitioner has statutory remedy under the Income Tax Act, 1961 which hemay avail by filing revision petition before the jurisdictional PrincipalCommissioner of Income Tax under section 264 or filing appeal before theCommissioner of Income Tax (Appeals) under section 250. The Petitioner has alsofiled application for witndrawal of Writ Petition to avail the remedy available underlaw. As such the Writ Petition is liable to be dismissed.” 10. In instructions/ Circular F.No.225/290/2015-ITA-II, dated 09.11.2015issued by the Government of India, Ministry of Finance, Department ofRevenue (CBDT), the Central Board of Direct Taxes (for short “CBDT”) itselfhas noted that “it has been brought to the notice of Board that the tendency toframe high-pitched and unreasonable assessment orders is still persisting dueto which grievances are being raised by the taxpayers. Such grievances notonly reflect harassment of taxpayers but also lead to generation ofunproductive work for Department as well as Appellate Authorities.” Underthe aforesaid instructions dated 09.11.2015, Local Committees wereconstituted to resolve quickly the taxpayers' grievances on account of high-pitched and unreasonable additions made by the Assessing Authorities. But itappears that tendency to frame high-pitched and unreasonable assessmentorders is still persisting as also acknowledged by the respondents whichresulted in issuance of instructions/ Circular dated 23.04.2022 under Section119 of the Income Tax Act, 1961 so as to give it statutory backing. 11. This Court is also frequently coming across the writ petitions in whichimpugned orders reflect non-observance of principles of natural justice andeven reply submitted by assessees are not being considered by AssessingOfficers under the faceless regime as well as non-faceless regime under theAct, 1961. 11. This Court is also frequently coming across the writ petitions in whichimpugned orders reflect non-observance of principles of natural justice andeven reply submitted by assessees are not being considered by AssessingOfficers under the faceless regime as well as non-faceless regime under theAct, 1961. 12. Tax payers are one of the important pillars of economy of the country.Their harassment not only causes jolt to the economy of the country andemployment but also comes in the way of economic policy of the governmentincluding the policy “Ease of Doing Business”. The instructions dated23.04.2022 issued by the CBDT, in exercise of powers conferred underSection 119 of the Act, 1961 and statement made by the respondent No.4 inthe aforequoted para-10 of the personal affidavit dated 19.05.2022, needs to beimplemented truly and effectively. Therefore, necessary mandamus needs tobe issued to the respondents. 13. In view of the aforesaid, the writ petition is disposed off giving libertyto the petitioner to avail statutory remedy of appeal or revision under the Act,1961 as he may be advised. All pending applications are disposed off. 14. In view of the discussions made above, particularly considering theinstructions dated 23.04.2022 issued by the CBDT in exercise of powersconferred under Section 119 of the Act, 1961 and the statement of therespondent No.4 made in para-10 of the personal affidavit filed on 19.05.2022,the following directions in the nature of mandamus are issued:- (i) The respondent No.4 shall ensure that copies of instructionsF.No.225/101/2021-ITA-II, Government of India, Ministry of Finance,Department of Revenue, Central Board of Direct Taxes dated23[rd] April, 2022is circulated within a month from today to Tax Bar Associations at DistrictLevel, State Level and National Level for information along with thefollowing contents of paragraph-10 of the personal affidavit dated19.05.2022:- “The said instruction also provides for initiation of suitableadministrative action against the erring officer in case whereassessments are found by the local committee to be high-pitched orwhere there is non-observance of principles of natural justice, non-application of mind or gross negligence of assessing officer/Assessment Unit.” (ii) The respondent No.4 shall ensure that the aforesaid instructions dated23.04.2022 along with afore-quoted contents of paragraph-10 of the personalaffidavit dated 19.05.2022 shall be displayed on the official website of theIncome Tax Department for awareness and information of taxpayers andconsultants. (iii) The constitution of Local Committees, procedure for submissions,receipts and disposal of grievances as provided in the aforesaid instructionsdated 23.04.2022 and the above noted contents of the paragraph 10 of thepersonal affidavit dated 19.05.2022, for the purposes of publicity andawareness amongst taxpayers/ assessees to achieve the mandate of Clause2.A.(iv) of the aforesaid instructions dated 23.04.2022, shall be published regularly for one year at least once in three months in two NationalNewspapers (one in English and the other in Hindi) and two State LevelNewspapers (one in Hindi or Local Language and the other in English). (iv) In the event “Local Committees” as referred in Clause 2.A.(i) of theaforesaid instructions dated 23.04.2022 in all the regions across the countryincluding Pr.CCIT (Exemptions) and Pr.CCIT (International Taxation) havenot yet been constituted, then the respondent No.4 shall ensure that LocalCommittees as provided in Clause 2.A.(i) of the aforesaid instructions dated23.04.2022 be constituted within fifteen days from today and be madefunctional. regularly for one year at least once in three months in two NationalNewspapers (one in English and the other in Hindi) and two State LevelNewspapers (one in Hindi or Local Language and the other in English). (iv) In the event “Local Committees” as referred in Clause 2.A.(i) of theaforesaid instructions dated 23.04.2022 in all the regions across the countryincluding Pr.CCIT (Exemptions) and Pr.CCIT (International Taxation) havenot yet been constituted, then the respondent No.4 shall ensure that LocalCommittees as provided in Clause 2.A.(i) of the aforesaid instructions dated23.04.2022 be constituted within fifteen days from today and be madefunctional. (v) The respondent No.4 shall ensure to establish a monitoring cell at thelevel of Government or CBDT within a month from today, if not establishedso far, which shall ensure regular monitoring of the Local Committees, followup actions and review by Principal Chief Commissioners of Income Tax andZonal Members, and analyse the quarterly reports for effectiveimplementation of the instructions dated 23.04.2022 and the statement madein paragraph 10 of the personal affidavit dated 19.05.2022 aforequoted. (vi) The Local Committee shall dispose off each grievance petition withintwo months from the end of the month in which grievance petition is receivedby it and its result and action taken on administrative side, if any, shall becommunicated in writing to the concerned assessee within next four weeks. (vii) The CBDT shall regularly monitor and shall take all necessary stepsfrom time to time for effective implementation of the scheme/ instructionsdated 23.04.2022 and necessary modifications/ improvements therein in theinterest of assessees so as to achieve the object of the aforesaid scheme/policy decision/ instructions dated 23.04.2022.Order Date :- 19.05.2022 NLY