https://www.taxtmi.com/caselaws?id=429053 A show cause notice-cum-draft assessment order issued late at night, with only about 24 hours to respond under the faceless assessment procedure, was treated as not providing a real and reasonable opportunity of hearing. Because the assessee had insufficient time to notice the communication, prepare a reply, and seek a hearing, the resulting assessment process was found procedurally unfair. The assessment orders were set aside and the matter was remanded for fresh consideration after granting adequate time to respond in accordance with law; the connected penalty orders were kept in abeyance until reassessment is completed. en-us Fri, 09 Sep 2022 00:00:00 +0530 Mon, 20 Jan 2025 10:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429053 A show cause notice-cum-draft assessment order issued late at night, with only about 24 hours to respond under the faceless assessment procedure, was treated as not providing a real and reasonable opportunity of hearing. Because the assessee had insufficient time to notice the communication, prepare a reply, and seek a hearing, the resulting assessment process was found procedurally unfair. The assessment orders were set aside and the matter was remanded for fresh consideration after granting adequate time to respond in accordance with law; the connected penalty orders were kept in abeyance until reassessment is completed. Case-Laws Income Tax Fri, 09 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429053