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The HC held that the assessment order passed under section 143(3) read with section 144B was invalid due to denial of natural justice, as the petitioner was granted only four effective days to respond to the show-cause notice issued on 28.02.2025. The court found that the Department had ample time to issue the notice earlier and complete the assessment within the statutory period. The short notice period, compounded by non-working days, was held to be unreasonable. Consequently, the show-cause notice and the subsequent assessment order dated 11.03.2025 were quashed. The matter was remitted to the assessing authority to allow the petitioner a fresh opportunity to file a detailed response within seven days, with the authority directed to facilitate submission by reopening the relevant portal.
The HC held that the assessment order passed under section 143(3) read with section 144B was invalid due to denial of natural justice, as the petitioner was granted only four effective days to respond to the show-cause notice issued on 28.02.2025. The court found that the Department had ample time to issue the notice earlier and complete the assessment within the statutory period. The short notice period, compounded by non-working days, was held to be unreasonable. Consequently, the show-cause notice and the subsequent assessment order dated 11.03.2025 were quashed. The matter was remitted to the assessing authority to allow the petitioner a fresh opportunity to file a detailed response within seven days, with the authority directed to facilitate submission by reopening the relevant portal.
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