Allowing the petition the Court held that  the assessment order had been passed in contravention of the basic principles of natural justice and fair play, inasmuch as the assessee was not granted an opportunity to file its reply to the proposed additions and a further opportunity of being heard in the matter and hence the order was unsustainable. Therefore, the assessment order with the consequential notice of demand and notice for initiating penalty proceedings were set aside. However, liberty was given to the Department to proceed in the matter in accordance with law after affording an opportunity of being heard to the assessee in response to the show-cause notice.  (AY. 2018-19)