Natural justice in faceless assessment proceedings requires consideration of adjournment requests and replies before passing an assessment order.

An assessment order is vitiated where the assessee's adjournment request and filed reply are not considered and the hearing date is not clearly intimated, because this denies a fair opportunity of hearing and breaches natural justice in faceless assessment proceedings. On those facts, the Delhi HC quashed the assessment order and the consequential demand notice, and remanded the matter for fresh assessment after granting the assessee due opportunity to respond.

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Issues: Whether the assessment order was vitiated for breach of natural justice on account of non-consideration of the adjournment request and the reply filed by the assessee.

Analysis: The assessee had sought time to file a reply and there was no clear material to show that the request was rejected or that the next date of hearing was duly intimated. The record also showed that the reply filed on the relevant date was not considered before passing the assessment order. In such circumstances, the assessee's opportunity of hearing stood denied, and the procedural fairness expected in faceless assessment proceedings was not followed.

Conclusion: The assessment order and the consequent demand notice were quashed, and the matter was remanded for fresh assessment after giving the assessee due opportunity of hearing.

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