Reasonable opportunity of hearing requires adequate response time and consideration of hearing requests before completing assessment.

An assessment order cannot stand where a show-cause notice issued on a Sunday allows only three days for response and the taxpayer's subsequent reply and request for a video-conference hearing are not considered. Such limited time fails to provide a reasonable opportunity of being heard, and the grievance concerning inadequate response time must be addressed before assessment is completed. The assessment was vitiated for breach of natural justice, requiring a fresh assessment after adequate hearing opportunity, including a personal hearing where permitted by law.

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Issues: Whether the assessment order could stand where the assessee was allowed only three days to respond to the show-cause notice and its subsequent grievance seeking a hearing was not considered.

Analysis: The show-cause notice, issued on a Sunday, allowed only three days for a response. The assessee thereafter submitted its reply and grievance requesting a video-conference hearing, but the assessment order was passed without considering them. Such limited time did not constitute a reasonable opportunity, and the grievance concerning inadequate time required consideration before completing the assessment.

Conclusion: The assessment order was vitiated by breach of the principles of natural justice; the assessee was entitled to a fresh assessment after an adequate opportunity of hearing, including personal hearing where permissible in law.

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