Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI • Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions • Judicial precedents and Supreme Court, High Court and other citations • Issue-wise legal analysis • Practical arguments and supporting content • Professionally structured draft ready for further review.
Tax Assessment Overturned Due to Natural Justice Violation; Online Hearing Ordered for Reassessment. The HC quashed the assessment order dated 31st March 2024 under section 143(3) of the Income Tax Act, 1961, due to a violation of natural justice. The ...
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Tax Assessment Overturned Due to Natural Justice Violation; Online Hearing Ordered for Reassessment.
The HC quashed the assessment order dated 31st March 2024 under section 143(3) of the Income Tax Act, 1961, due to a violation of natural justice. The Court found that the petitioner was not given a reasonable opportunity to respond to the show-cause notice. The assessment order was set aside, and the matter was remanded for reconsideration, mandating the faceless assessment unit to consider the previously submitted response and provide a personal hearing via online video conference within six weeks. The writ petition was disposed of with instructions for compliance based on the official order.
Issues: Challenge to assessment order u/s 143(3) of the Income Tax Act, 1961 on grounds of violation of natural justice.
Summary: The petitioners sought to add a co-petitioner and challenged an assessment order dated 31st March 2024 u/s 143(3) of the Income Tax Act, 1961, alleging a violation of natural justice. The petitioner company, a private entity, received a show-cause notice on 26th March 2024, requiring a response by 27th March 2024. Due to a holiday on 26th March, the response was submitted on 30th March 2024. Despite this, the faceless assessment unit did not consider the response, leading to the petitioners claiming a lack of reasonable opportunity to respond.
The Court acknowledged that the show-cause notice was digitally signed on 26th March 2024, after working hours, giving the petitioner only 24 hours to respond. Considering the response submitted on 30th March 2024, the Court held that the assessment unit should have considered it. The Court criticized the mechanical approach of the assessment unit in not acknowledging the response and set aside the assessment order, remanding the matter for a fresh decision with an opportunity for a personal hearing via online video conference.
The Court quashed the order dated 31st March 2024 and directed the faceless assessment unit to reconsider the matter based on the response already submitted by the petitioner, providing an opportunity for a personal hearing within 6 weeks. The writ petition was disposed of with the directive that all parties act based on the official order downloaded from the Court's website.
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