Minimum response period in reassessment notices: a notice granting less than seven days was held invalid.

A notice issued for reassessment gave the assessee less than seven days to respond, contrary to the minimum period required. The governing jurisdictional High Court authority was applied to treat the shortened response time as prejudicial and violative of natural justice. On that basis, the notice and the consequential reassessment proceedings were held unsustainable, and the assessee's objection succeeded.

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Issues: Whether a notice issued under section 148A(b) of the Income-tax Act, 1961, granting less than seven days' time to respond, vitiated the reassessment proceedings.

Analysis: The notice afforded less than the minimum period of seven days for filing a reply. The issue was treated as covered by binding jurisdictional High Court authority holding that not less than seven days must be granted, and that denial of such time causes prejudice and violates natural justice. The impugned notice and the consequential proceedings were therefore considered unsustainable.

Conclusion: The notice under section 148A(b) was invalid for breach of the minimum statutory time requirement, and the assessee's objection succeeded.

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