Portal service dispute leads to reopening of assessment, with fresh hearing allowed after partial tax deposit.

Where assessment notices and the impugned order were uploaded on the common portal and the assessee claimed inability to access them, the Madras HC accepted that an additional opportunity should be given. It allowed the assessment to be reopened by treating the assessment order as a show cause notice, subject to deposit of 25% of the disputed tax and filing objections within time. The respondent was directed to consider the objections and pass fresh orders after granting a reasonable opportunity of hearing.

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Issues: Whether the assessment order was liable to be set aside and the matter remanded on the ground of alleged non-service of notices and denial of effective opportunity to participate in the adjudication.

Analysis: The assessment proceedings were challenged on the basis that the notices and the impugned order had been uploaded in the common portal and the petitioner claimed inability to access the portal. The Court accepted the request for an additional opportunity, noticed the petitioner's willingness to deposit 25% of the disputed tax, and proceeded to reopen the matter by treating the assessment order as a show cause notice upon compliance with the deposit condition. The respondent was directed to consider the objections and pass fresh orders after granting a reasonable opportunity of hearing.

Conclusion: The assessment order was set aside and the matter was remanded for fresh consideration subject to deposit of 25% of the disputed tax and filing of objections within the stipulated time.

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