Supply of seized documents and right to file a supplementary reply permitted, with prescribed timelines and one personal hearing opportunity.

Petitioner was granted access to specified copied and digital versions of seized office files and enumerated documents, and the State shall place those copies on record by affidavit; this supply was ordered on short timelines to enable effective response. The petitioner was allowed time until 18.12.2025 to file a supplementary reply-affidavit and one further personal hearing on 22.12.2025. The Assessing Officer/Adjudicating Officer is permitted to consider the supplementary reply and pass assessment orders within the statutory limitation period thereafter.

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Issues: Whether the petitioner should be granted copies/digital copies of seized office documents and additional time and opportunity to file a supplementary reply and for personal hearing so that the State Tax Department can decide the assessment within the statutory period.

Analysis: The Court examined the record showing which box files and office files were already returned and which office files and enumerated documents remained to be supplied. The State Tax Department stated that photocopies and a pen drive containing digital copies of the specified office files and six enumerated documents have been prepared and would be placed on record by affidavit. The Court weighed the need for supply of documents to enable effective reply, the petitioner's request for time to file a supplementary reply in light of the supplied documents, and the requirement that assessment orders be passed within the statutory limitation period (last date indicated for assessment year 2018-19). On consent, the Court directed specific short timelines for supply/compliance and for filing of the supplementary reply-affidavit and granted one further opportunity for personal hearing; the Assessing Officer/Adjudicating Officer was permitted to pass orders within the statutory period after considering the petitioner's supplementary reply.

Conclusion: The petitioner is granted the relief sought limited to supply of the specified copied documents/digital copies and time till 18.12.2025 to file a supplementary reply-affidavit, and one further opportunity for personal hearing on 22.12.2025; the Assessing Officer/Adjudicating Officer is at liberty to decide the matter within the statutory period.

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