Yes, denying a proper opportunity for a personal hearing during faceless assessments under the Income Tax Act, 1961, could be seen as infringing upon the principles of natural justice, particularly the right to be heard, which is implied under Article 14 (equality before the law) and Article 21 (right to life and personal liberty) of the Indian Constitution.

Faceless Assessment Under the Income Tax Act, 1961 & Compliance with Natural Justice (Article 14 & 21)
The Faceless Assessment Scheme, introduced under Section 144B of the Income Tax Act, 1961, aims to eliminate human interface, reduce corruption, and ensure objectivity in tax assessments. However, the exclusion of a personal hearing has raised constitutional concerns regarding natural justice under Article 14 (Equality) and Article 21 (Due Process) of the Indian Constitution.

1. Legal Framework of Faceless Assessment
No Personal Hearing Mandated: The scheme relies on written submissions and e-communications between taxpayers and the National e-Assessment Centre (NeAC).

Exception: A limited video conferencing hearing may be allowed in "complex cases" (Rule 129 of Income Tax Rules).

Judicial Review: Taxpayers can appeal to CIT(A) or tribunals, but no oral hearing at the initial assessment stage.

2. Principles of Natural Justice in Taxation
Natural justice requires:

Audi Alteram Partem (Right to Hearing): The assessee must have a fair opportunity to present their case.

Reasoned Orders: Authorities must provide clear, logical findings.

Key Precedents on Natural Justice & Tax Assessments
State of Kerala v K.T. Shaduli Yusuf (1977): Denial of a hearing violates natural justice.

Dhakeswari Cotton Mills Ltd. v CIT (1954): Even quasi-judicial tax proceedings must follow fair procedure.

Maneka Gandhi v UoI (1978): Article 21 includes procedural fairness in state actions.

3. Does Faceless Assessment Violate Natural Justice?
Arguments in Favor of Constitutionality
✅ Efficiency & Transparency: Reduces bias and delays.
✅ Written Submissions Suffice: If detailed responses are permitted, oral hearings may not be essential (CIT v Jai Shiv Shankar Traders, 2021).
✅ Alternative Remedies: Assessees can appeal to higher forums (CIT(A), ITAT) where hearings are allowed.

Arguments Against Constitutionality
❌ No Effective Oral Hearing: Complex tax disputes often require clarifications, cross-examination, or expert explanations, which written submissions may not adequately address.
❌ Violation of Article 14 & 21:

Article 14: Arbitrary exclusion of hearings for some taxpayers (e.g., small vs. large cases) may be discriminatory.

Article 21: Deprivation of a meaningful opportunity to defend could be procedurally unfair.
❌ Judicial Precedents:

In Tata Cellular v UoI (1994), the SC held that administrative efficiency cannot override fairness.

CIT v Sahara India (2008): Denial of hearing where facts are disputed violates natural justice.

4. Judicial Trends on Faceless Assessments
Varinder Mehta v NFAC (2021, Delhi HC): Upheld faceless assessment but emphasized that procedural fairness must be ensured.

Sahara Hospitality v PCIT (2022, Allahabad HC): Suggested that denial of hearing in complex cases may be unjust.

Pending Supreme Court Challenge: Petitions argue that Rule 129 (allowing hearings only in "complex cases") is arbitrary.