Riddhi Steel and Tube Ltd. v NFAC(2022) 145 taxmann.com 542 /(2023)457 ITR 105 (Guj)(HC)

S. 144B : Faceless Assessment-Principle of natural justice-Variation proposed in draft assessment order-Must be given an opportunity to be heard. [S. 144B(7), 144B(1)(xvi), Art. 226]

Held that the show-cause notice dated September 18, 2021 was issued with a direction to file reply by September 20, 2021. September 18, 2021 was Saturday and September 20, 2021 was Monday, and the assessment order was passed on September 21, 2021. Thus there was clear violation of the principles of natural justice. The order of assessment dated September 21, 2021 for the assessment year 2013-14 passed by the respondent-authority under section 147 read with section 144B of the Act with the demand notice under section 156 of the Act were quashed and set aside.(AY.2013-14)