Court emphasizes natural justice in setting aside rectification order, granting petitioner right to file objections and have a hearing.

The court set aside the rectified order and demand notice, directing the respondent to provide detailed interest workings to the petitioner. The court emphasized the importance of adhering to principles of natural justice, ordering the respondent to allow the petitioner to file objections and have a hearing before passing a consolidated order on the rectification application and proposed interest levy. The writ petition was disposed of in favor of the petitioner, ensuring her right to be heard and defend against the rectification proposal.

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Issues:
1. Rectification application under Section 154 of the Income Tax Act for the year 1989-90 pending.
2. Notice received proposing rectification for short levy of interest under Section 234A and B.
3. Failure to provide detailed working of interest before passing rectified order.
4. Violation of principles of natural justice in passing the order without providing details sought by the petitioner.

Analysis:
1. The petitioner filed an application (Ext.P1) for rectification of the assessment order for the year 1989-90 under Section 154 of the Income Tax Act. However, orders have not been passed on that application, and it is still pending. The petitioner requested the respondent to consider the pending application and pass orders accordingly.

2. Subsequently, the petitioner received a notice (Ext.P2) from the respondent proposing to rectify the assessment order due to the short levy of interest under Section 234A and B of the Act. Upon receiving this notice, the petitioner requested detailed working of the interest (Ext.P3), which was not provided by the respondent. Despite the lack of details, a rectified order (Ext.P4) and a demand notice (Ext.P5) were issued to the petitioner based on the proposed rectification.

3. The petitioner argued that the order (Ext.P4) was passed without furnishing the details of the interest sought by her, depriving her of the opportunity to file objections. The court found that the failure to provide the details before passing the order violated the principles of natural justice. Consequently, the court set aside the order (Ext.P4) and the demand notice (Ext.P5), directing the respondent to furnish the detailed working of the interest proposed in Ext.P2 to the petitioner.

4. The court ordered that once the details are provided, the petitioner should be allowed to file objections to Ext.P2 and be given an opportunity for a hearing. Subsequently, a consolidated order on Exts.P1 and P2 should be passed by the respondent, ensuring that the petitioner's right to be heard and defend against the proposed rectification is upheld. The writ petition was disposed of in favor of the petitioner, emphasizing the importance of adhering to the principles of natural justice in such proceedings.

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