Faceless assessment response period must meet SOP requirements; inadequate notice time breaches natural justice and requires fresh consideration.

A faceless-assessment show-cause notice must allow at least seven days for a response under the applicable SOP. Allowing only six days deprives the assessee of the prescribed opportunity to respond and breaches principles of natural justice. Earlier lack of diligence by the assessee does not cure this procedural defect in the notice under challenge. The assessment and consequential orders were set aside, with the matter restored to provide a fresh opportunity to respond to the show-cause notice.

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Issues: Whether an assessment founded on a show-cause notice allowing less than seven days for response, contrary to the applicable faceless-assessment SOP, was liable to be set aside.

Analysis: Clause N.1.3 of the applicable SOP requires at least seven days for responding to a show-cause notice. The impugned notice allowed only six days. This procedural illegality deprived the assessee of the stipulated opportunity to respond and violated principles of natural justice. Alleged lack of diligence in earlier proceedings did not cure the defect in the notice under challenge.

Conclusion: The assessment and consequential orders were set aside and the matter was restored for a fresh opportunity to reply to the show-cause notice, in favour of the assessee.

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