Allowing the writ petitions the Court held that   the Assessing Officer had inadvertently overlooked the e-mail reply dated July 20, 2022, of the assessee, wherein the assessee had not just sought extension of time till August 5, 2022, to respond but also disclosed vital facts pertaining to its case. Denial of sufficient time to respond was not just an abrogation of jus naturale but also infringed clause B(1) of the Standard Operating Procedure dated November 19, 2020, of the Central Board of Direct Taxes, according to which normally a response time of 15 days has to be given to the assessee in order to respond to the notice under section 142 of the Act. The draft assessment orders dated July 26, 2022, final assessment orders dated September 10, 2022, the demand notices dated September 10, 2022 and the penalty orders dated March 30, 2023 were set aside. The matter was remanded back to the Assessing Officer with the direction to afford a fair hearing to the assessee in accordance with law after issuing fresh notices under section 142(1) of the Act.(AY.2015-16, 2016-17)