The assessee was issued a show cause notice under Section 144B. A day before the 09.12.2022 deadline, the assessee e-mailed an adjournment request seeking an extension. The department, however, did not communicate any decision on this request and closed the portal window on the original due date. When the assessee attempted to upload its reply on the requested extended date, it was unable to do so, and an assessment order was subsequently passed on 17.12.2022. The High Court observed that Section 144B(1)(xiii) allows for an extension of time based on an application. By failing to act on the adjournment request and closing the portal, the department had denied the assessee a proper opportunity of being heard. Accordingly, the Court quashed the assessment order and directed the department to reopen the portal to enable the assessee to file its reply and also to grant a personal hearing, if sought. (AY. 2021-22)