Natural justice in assessment proceedings: order set aside and remand ordered after denial of opportunity on portal access issues.

Assessment proceedings were challenged on the ground that notices and the order were uploaded on the common portal, while the taxpayer claimed inability to access the portal and denial of opportunity. The Court accepted the request for one further opportunity, subject to the taxpayer depositing 10% of the disputed tax and filing objections within the stipulated time. The assessment order was set aside and the matter was remanded for fresh consideration, preserving the taxpayer's chance to contest the assessment on merits.

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Issues: Whether the assessment order was liable to be set aside and the matter remanded for fresh adjudication on the ground of denial of opportunity.

Analysis: The assessment proceedings were challenged on the basis that the notices and order were uploaded in the common portal and the petitioner claimed inability to access the portal. The petitioner expressed readiness to pay 10% of the disputed tax and to file objections if one further opportunity was granted. The respondent did not seriously oppose such course.

Conclusion: The impugned assessment order was set aside, the matter was remanded for reconsideration, and the petitioner was directed to comply with the condition of depositing 10% of the disputed tax and filing objections within the stipulated time.

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