Inadequate opportunity under section 142(1) led to breach of natural justice and remand for fresh assessment.

An assessment completed under sections 144 and 147 was held invalid where the section 142(1) notice allowed only a very short time for compliance and the assessee had sought additional time to file remaining documents. The limited opportunity was treated as inadequate for a meaningful response, so the assessment was found to have breached natural justice and was set aside. The matter was remanded for fresh consideration from the notice stage, and the assessee's request for reasons for reopening was left open for reconsideration.

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Issues: Whether the assessment order passed under Sections 144 and 147 of the Income-tax Act, 1961 was liable to be set aside for want of reasonable time in response to the notice under Section 142(1), and whether the matter should be remanded for fresh consideration.

Analysis: The notice under Section 142(1) afforded only a very short interval for compliance, and the assessee responded partially while specifically seeking time to furnish the balance documents. The time granted was held to be inadequate for a meaningful response. In these circumstances, the assessment was found to have been completed in breach of the principles of natural justice. The Court also left open the assessee's request for reasons for reopening and directed that the matter be reconsidered afresh from the notice stage.

Conclusion: The assessment order was set aside on the ground of inadequate opportunity, and the matter was remanded for de novo assessment.

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