SN Advance Ventures Private Limited Vs ACIT (Gujarat High Court)
The Gujarat High Court allowed the writ petition filed by SN Advance Ventures Private Limited challenging the assessment order dated 17.03.2026 passed under Section 143(3) read with Section 144B of the Income Tax Act, 1961 for Assessment Year 2024-25.
The petitioner, a private limited company whose shareholders are individuals and citizens of India, had filed its return of income for AY 2024-25 on 20.10.2024 declaring a total income of Rs.1,05,91,080/-. The case was selected for scrutiny assessment, and the petitioner complied with notices issued by the respondents by filing replies from time to time.
The dispute arose after the petitioner received a Show Cause Notice dated 08.03.2026, which was issued on a Sunday and granted time only until 11.03.2026, amounting to three days for filing a response. The petitioner contended that the time granted was grossly insufficient and contrary to the settled principles requiring a reasonable opportunity. According to the petitioner, before it could even seek an adjournment, the proceedings were closed, depriving it of an effective opportunity to respond.
On 16.03.2026, the petitioner submitted a grievance bearing Acknowledgment No. 25223006 requesting an opportunity of hearing through video conference. It also emailed its grievance and reply on the same date. Despite this, the assessment order was passed on 17.03.2026 without considering the grievance or granting any hearing.
