Natural justice requires reasonable time for pre-assessment objections and a reasoned decision on extension requests.

Where a pre-assessment notice fixes only a time for objections and not a statutory limitation period, fairness requires the assessing authority to consider a request for extension when circumstances justify it. The assessment was made mechanically after the assessee sought more time because its books were with the income-tax authorities, and the rejection of extension was unreasoned. That approach violated the principles of natural justice. The assessment order was set aside, and the matter was remitted for fresh consideration after granting time to file objections and an opportunity of hearing.

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Issues: Whether the assessment order could be sustained when the assessee was not granted reasonable time to file objections to the pre-assessment notice and the request for extension of time was rejected without reasons.

Analysis: The assessment was made after the assessee sought further time to submit objections on the ground that its books of account were with the income-tax authorities and required examination before filing a proper response. The prescribed date for objections was not a statutory limitation period but only a time fixed by the assessing authority. In such a situation, fairness required the authority to consider extension of time where the circumstances so demanded. Passing the assessment mechanically on the expiry of the stated time, without affording a reasonable opportunity and without assigning reasons for rejecting the request, offended the principles of natural justice.

Conclusion: The assessment order was set aside and the matter was directed to be reconsidered after giving the assessee time to file objections and an opportunity of hearing.

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