Order under Section 147 and 144B invalid for denying proper time to submit evidence, violating natural justice principles

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....The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.....