Natural justice in assessment proceedings requires consideration of manually filed replies and a personal hearing before finalisation.

An Assessing Officer cannot ignore an assessee's reply merely because it was filed manually rather than through the portal; the reply must be considered before finalising assessment. Where the manual reply and supporting documents were not considered and no personal hearing was granted, the assessment was made mechanically in breach of natural justice. The assessment order and rectification order were therefore set aside, and the matter was remanded for fresh consideration after granting a personal hearing on 14 clear days' notice. The consequential recovery notice was also quashed.

---

---

Issues: Whether the assessment orders and consequential rectification order were liable to be set aside for failure to consider the assessee's manually filed reply and for want of a personal hearing, and whether the consequential recovery notice was also liable to be quashed.

Analysis: The dispute turned on whether the assessing authority could ignore a reply merely because it was filed manually rather than through the portal. The order holds that, irrespective of the mode of filing, the Assessing Officer is bound to consider the assessee's reply before finalising the assessment. Since the reply and supporting documents were admittedly filed manually but not considered, and no personal hearing was afforded, the assessment was found to have been made mechanically and in breach of natural justice. The recovery notice was consequential to the impugned assessment proceedings.

Conclusion: The assessment order and rectification order were set aside, the matter was remanded for fresh consideration after considering the manual reply and granting a personal hearing on 14 clear days' notice, and the consequential recovery notice was quashed.

---