Right to be heard: faceless assessments without opportunity to reply or personal hearing must be set aside and reheard.

Failure to afford an assessee the mandated opportunity to file a reply to a show-cause notice and to obtain personal hearing in faceless assessment proceedings under the remand direction violates the principles of natural justice and renders the proceedings procedurally infirm. Consequentially, the impugned assessment and demand were set aside, the assessee permitted to file her reply to the notice, and a personal hearing must be afforded before any fresh assessment is completed. The decision directs reassessment only after compliance with the remand and hearing requirements.

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Issues: Whether the assessment order dated 04.12.2025 passed under Section 144 read with Section 144B of the Income-tax Act, 1961, together with the consequential demand notice dated 04.12.2025 under Section 156, is vitiated by denial of opportunity to file reply and denial of personal hearing as directed by the appellate authority.

Analysis: The remand by the appellate authority required fresh assessment after affording sufficient opportunity to the assessee. Proceedings were conducted under the faceless assessment framework invoking Section 144B and Section 144 of the Income-tax Act, 1961, and notices under Section 142(1) were issued seeking explanations. The record shows that the assessee was unable to e-file her reply due to portal closure, lodged a grievance which was not remedied, and was not offered personal hearing before the impugned order was passed. Failure to provide the statutory and remand-directed opportunity to file a reply and to be heard engages the principles of natural justice and renders the assessment process unfair and procedurally infirm.

Conclusion: The impugned assessment order dated 04.12.2025 and the demand notice dated 04.12.2025 are set aside; the assessee is permitted to file her reply to the show cause notice and shall be afforded opportunity of hearing before fresh assessment is completed; writ petition allowed in favour of the assessee.

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