Natural justice in assessment proceedings: denial of requested video conference hearing led to quashing and remand for fresh adjudication.

An assessment order passed under Section 143(3) read with Section 144B was held vulnerable where the assessee's request for a hearing through video conference was not considered before disposal. The Court treated the omission as a breach of natural justice because the requested hearing was material to the decision-making process. The assessment order was quashed and set aside, and the matter was remanded to the Assessing Officer for fresh de novo adjudication after granting an opportunity of hearing through video conference in accordance with law.

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Issues: Whether the assessment order passed under Section 143(3) read with Section 144B of the Income-tax Act, 1961 was liable to be quashed for denial of opportunity of hearing through video conference, and whether the matter required remand for fresh consideration.

Analysis: The petition was entertained on the limited ground of breach of natural justice. The record showed that the petitioner had requested a hearing through video conference, but the request was not considered before passing the impugned assessment order. In these circumstances, the absence of a personal hearing through video conference amounted to non-adherence to the principles of natural justice.

Conclusion: The impugned assessment order was quashed and set aside, and the matter was remanded to the Assessing Officer to pass a fresh de novo order after granting an opportunity of hearing through video conference in accordance with law.

Ratio Decidendi: An assessment order passed without granting a requested hearing through video conference, where such hearing is material to the decision-making process, is vitiated for breach of the principles of natural justice and is liable to be set aside with remand for fresh adjudication.

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