Court sets aside assessment orders due to procedural errors and lack of natural justice, grants petitioners opportunity to respond.

The court found multiple violations of natural justice principles, including non-receipt of show cause notices, lack of personal hearings, errors in assessment orders, and non-compliance with procedural requirements under the Faceless Assessment Scheme. Assessment orders were set aside in various cases due to these issues. The court directed petitioners to be given an opportunity to respond and be heard personally. Respondents were instructed to complete reassessment within 90 days, with impugned orders standing revived if petitioners failed to respond within the given time.

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Issues Involved:
1. Violation of principles of natural justice.
2. Non-receipt of show cause notices.
3. Lack of personal hearing.
4. Errors in assessment orders.
5. Non-compliance with procedural requirements under the Faceless Assessment Scheme.
6. Inadequate time for response to show cause notices.
7. Discrepancies between show cause notices and final assessment orders.
8. Additional issues addressed in final assessment orders not included in show cause notices.

Issue-wise Detailed Analysis:

1. Violation of Principles of Natural Justice:
- W.P.No.12572 of 2021: The petitioner claimed non-receipt of the show cause notice. The court found that the notice was not sent to the petitioner directly, violating principles of natural justice. The assessment order dated 31.03.2021 was set aside.
- W.P.No.13580 of 2021: The petitioner did not receive communication regarding the adjournment request, leading to a violation of natural justice. The assessment order dated 25.05.2021 was set aside.
- W.P.No.13821 of 2021: The petitioner did not receive physical notice or proper email communication. The assessment order dated 10.04.2021 was set aside.
- W.P.No.13990 of 2021: The petitioner was denied a personal hearing, which was deemed necessary for compliance with natural justice. The assessment order dated 21.06.2021 was set aside.
- W.P.No.15235 of 2021: The petitioner requested a personal hearing, which was not granted, violating natural justice. The assessment order dated 28.04.2021 was set aside.
- W.P.No.21334 of 2021: The petitioner's request for a personal hearing was ignored, leading to a violation of natural justice. The assessment order dated 21.09.2021 was set aside.
- W.P. No.12024 of 2021: The petitioner was not heard before the assessment order was passed, violating natural justice. The assessment order dated 23.04.2021 was set aside.

2. Non-receipt of Show Cause Notices:
- W.P.No.12572 of 2021: The show cause notice was sent to the Chartered Accountant's email, not directly to the petitioner. The assessment order was set aside.
- W.P.No.13821 of 2021: Notices were uploaded on the website without notifying the petitioner via SMS or email. The assessment order was set aside.

3. Lack of Personal Hearing:
- W.P.No.13990 of 2021: The petitioner requested a personal hearing, which was not provided. The assessment order was set aside.
- W.P.No.15235 of 2021: Despite requesting a personal hearing, the petitioner was not granted one. The assessment order was set aside.
- W.P.No.21334 of 2021: The petitioner's request for a personal hearing was ignored. The assessment order was set aside.

4. Errors in Assessment Orders:
- W.P.No.14118 of 2021: The assessment order contained errors and included issues not related to the petitioner. The draft order dated 08.05.2021 and the assessment order dated 07.06.2021 were set aside.

5. Non-compliance with Procedural Requirements:
- W.P.No.12572 of 2021: The procedure for sending notices was not followed. The assessment order was set aside.
- W.P.No.13580 of 2021: The officer did not communicate the decision on the adjournment request. The assessment order was set aside.
- W.P.No.13821 of 2021: Notices were uploaded without proper notification. The assessment order was set aside.
- W.P.No.13990 of 2021: The website did not have the feature for requesting a personal hearing. The assessment order was set aside.
- W.P.No.21334 of 2021: The extension of time for filing a reply was not communicated to the petitioner. The assessment order was set aside.

6. Inadequate Time for Response:
- W.P.No.12024 of 2021: The show cause notice granted very limited time for response, leading to inadequate opportunity to respond. The assessment order was set aside.

7. Discrepancies Between Show Cause Notices and Final Assessment Orders:
- W.P.No.14118 of 2021: The final assessment order addressed additional issues not included in the show cause notice. The assessment order was set aside.
- W.P.No.12024 of 2021: The final assessment order dealt with additional issues not proposed in the show cause notice. The assessment order was set aside.

8. Additional Issues Addressed in Final Assessment Orders:
- W.P.No.14118 of 2021: The final assessment order included issues beyond those in the show cause notice. The assessment order was set aside.
- W.P.No.12024 of 2021: The final assessment order addressed additional issues not included in the show cause notice. The assessment order was set aside.

Common Orders:
- In all cases, the court directed that the petitioners be given an opportunity to file replies and be heard personally. The assessment orders were set aside, and the respondents were instructed to complete the reassessment process within 90 days from the date of receipt of the certified copy of the order. If the petitioners failed to respond within the given time, the impugned orders would stand revived without further reference.

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