The CIT(E) issued notice u/s. 12A(1)(ac)(ii) and subsequent reminders which were reflected only on the portal instead of sending the same on the assessee’s email address. The assessee challenged the same as it was not provided sufficient opportunity. Revenue contended that as the assessee had submitted his form himself on the said e-portal, a presumption can be drawn that he was having knowledge of the notice/reminders which were placed on the e-portal as there was no requirement of submitting notice personally through e-mail or otherwise. However, High Court rejected the contentions of the Revenue and held that an individual or a Company is not expected to keep the e-portal of the Department open all the time so as to have knowledge of what the Department is supposed to be doing with regard to the submissions of forms etc.. The principles of natural justice are inherent in the income tax provisions and the same are required to be necessarily followed. Hence, the notices and order passed were set aside with the direction that the Department would provide an opportunity of hearing to the petitioner and they will also allow the petitioner to appear personally for the purpose and pass a speaking order independent of the order passed earlier by them.