Assessment quashed for denial of reasonable hearing; matter remanded to the Assessing Officer

5-Second Takeaway

The assessment order was quashed because the assessee was not given a reasonable opportunity of being heard. The Assessing Officer was directed to consider the grievance about the short three-day reply period and the request for a video-conference hearing, and to decide the matter afresh.

The petitioner’s scrutiny assessment was completed after it had sought more time and asked that its hearing be held through video conference. It filed a reply along with a grievance on 16 March 2026, specifically objecting to the inadequate time granted to respond.

The court held that, on the settled principles of natural justice, giving only three days to file a reply could not amount to a reasonable opportunity of hearing. It also found that the Assessing Officer should have considered and decided the petitioner’s grievance on the short time granted.

On that basis, the assessment order was quashed and set aside. The matter was remanded to the Assessing Officer for fresh consideration in accordance with law.