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Issues: Whether the impugned order could be sustained when the petitioner's reply to the show-cause notice had been furnished but was not considered, resulting in denial of a fair opportunity of hearing.
Analysis: The portal record showed that the reply had been received and was pending for consideration by the tax officer. In that view, the finding in the impugned order that no reply was filed was factually incorrect. Non-consideration of the reply meant that the petitioner's defence was not examined and the procedural safeguard of a fair hearing was denied, amounting to a violation of the principles of natural justice.
Conclusion: The impugned order could not be sustained and was set aside. The Authority was directed to consider the reply to the show-cause notice and proceed from that stage in accordance with law.