Faceless assessment must allow fair reply time and consider uploaded objections before finalising the assessment order.

Faceless assessment proceedings require a reasonable opportunity to respond to a show cause notice, and a curtailed reply period may be unjustified where the statutory framework contemplates seven days and limitation is not pressing. The assessee's uploaded reply must also be considered before finalising the assessment; failure to do so vitiates the order. Earlier requests for adjournment do not by themselves justify denial of a fair opportunity at a later stage. The assessment order was set aside and the matter remanded for fresh consideration after taking the reply into account.

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Issues: Whether the assessment order passed under the faceless assessment regime was liable to be set aside for denial of adequate opportunity to respond to the show cause notice and for non-consideration of the reply uploaded by the assessee.

Analysis: The show cause notice under the faceless assessment procedure was issued with only three days' time to reply, though the assessment limitation was still far away. The assessment framework contemplated a response period of seven days, and the curtailed time was found to be unjustified on the facts. The reply uploaded by the assessee before the impugned order was also not considered while finalising the assessment. The assessee's earlier requests for adjournment did not justify denial of a reasonable opportunity in the later stage of the proceedings.

Conclusion: The assessment order was rightly set aside and the matter was remanded to the assessing authority for fresh consideration after taking into account the assessee's reply.

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