Natural justice in tax assessment requires effective notice and meaningful reply opportunity; assessment quashed and remitted.

An assessment order cannot be sustained where the show cause notice was not effectively made available on the portal and the assessee was denied a meaningful opportunity to respond. The Madras HC treated the technical failure to upload the notice as a violation of natural justice, quashed the assessment, and remitted the matter to the assessing authority for fresh disposal on merits within three months. The assessee was permitted to file a reply, and the assessment order was to be treated as an addendum to the show cause notice.

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Issues: Whether the assessment order could be sustained when the show cause notice was not effectively made available on the portal and whether the matter required interference on the ground of violation of natural justice.

Analysis: The writ petition arose from a tax assessment order for the 2020-2021 period. The record indicated that the show cause notice was reflected on the portal, but the petitioner asserted that no accessible notice was available, and the respondents accepted that a technical glitch had prevented upload of the notice for response. In these circumstances, the order was passed without a proper opportunity to contest the proposal. As the petitioner had already deposited 10% of the disputed tax at the time of filing the appeal, the matter warranted fresh consideration on merits after affording an effective opportunity.

Conclusion: The impugned assessment order was quashed and the matter was remitted to the assessing authority for fresh disposal on merits within three months, with liberty to the petitioner to file a reply treating the assessment order as an addendum to the show cause notice.

Final Conclusion: The challenge succeeded on the ground of denial of effective opportunity, and the assessment was sent back for reconsideration in accordance with law.

Ratio Decidendi: An assessment order passed without effective service or availability of the show cause notice, thereby denying a meaningful opportunity to reply, is liable to be set aside and remanded for fresh adjudication.

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