A request for personal hearing was also made while seeking time till 21st April, 2021. On that day the assessee did file his reply to the show-cause notice.  However, the same has not been taken into consideration though the assessment order was passed much later on 14th May, 2021. Allowing the petition the Court held that the assessment order dt. 14th May, 2021 has been passed without granting proper and meaningful opportunity to the assessee to respond to the show-cause notice. A mere statement in the affidavit-in-reply that the assessee’s response to the show-cause notice did not contain any new or material fact cannot be accepted as such reason is not found in the impugned assessment order. Assessment order dt. 14th May, 2021 is set aside and proceedings are remanded to the respondent No. 1 for a fresh consideration in accordance with law after giving due opportunity of hearing to the assessee.