Held, allowing the petition, that it was an admitted fact that the assessee was initially residing at New Delhi and had shifted her residence from Delhi to Chennai in 2008. Hence, she was not at Delhi when the assessment order was passed. All the correspondence was sent to the old address of the assessee and she was intimated about the correspondence only in 2022. The assessee having submitted that if one last opportunity was provided to her to file a reply she would put forth her case before the Income-tax Officer, the order was set aside and the matter was remanded back to the Department, with a direction to provide an opportunity to the assessee for filing a reply and personal hearing. (AY.2012-13)
Vidya Ravichandran v. ITO (2025) 483 ITR 719 (Mad)(HC)
S. 144 : Best judgment assessment-Principle of natural justice-All correspondence sent to assessee’s old address-Intimation received by assessee at new address after three years-Direction to provide opportunity of hearing.[Art. 226]
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