Natural justice challenge fails when extended time is granted to reply but no response is filed before assessment.

An assessment order was not vitiated for breach of natural justice where the noticee sought and received extended time to reply, the second show cause notice was identical but fixed a fresh response date, and no reply was filed before the order was passed. On those facts, the court found the allegation of denial of adequate opportunity unsustainable and upheld rejection of the natural justice challenge. The writ appeal was dismissed, while the appellant was left to pursue the statutory appeal remedy with interim protection against coercive steps pending consideration of stay and appeal.

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Issues: Whether the assessment order was vitiated for violation of natural justice on the ground that the appellant was not given adequate opportunity to respond to the show cause notices.

Analysis: The appellant had sought and obtained extended time to reply to the first notice, and the second notice was identical to the first notice but fixed a fresh response date. Even after the further time sought by the appellant, no reply was filed before the assessment order was passed. On those facts, the claim of denial of natural justice was found unsustainable.

Conclusion: The challenge to the assessment order on the ground of violation of natural justice failed.

Final Conclusion: The writ appeal was dismissed, while the appellant was left to pursue the statutory appeal remedy with interim protection against coercive steps pending consideration of the stay application and appeal.

Ratio Decidendi: Where a noticee seeks and is afforded extended time to respond but still files no reply, an assessment cannot be set aside on the ground of violation of natural justice.

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