Mediacloud Studio Private Limited Vs Assessment Unit (Kerala High Court)
The Kerala High Court has overturned an assessment order against Mediacloud Studio Private Limited, ruling that a show cause notice (SCN) sent to an outdated email address, despite the company having updated its contact information on the tax portal, is invalid. This decision underscores the necessity for tax authorities to utilize the most current contact details provided by assessees.
Mediacloud Studio Private Limited challenged the assessment order for the assessment year 2023-24, asserting that it never received the crucial show cause notice. The company informed the court that its primary email address was changed from “[email protected]” to “[email protected]” and a secondary email “[email protected]” was added on September 20, 2024. These changes were duly updated on the tax portal and evidenced by Exhibit P5. However, when the show cause notice was issued on March 5, 2025, it was sent only to the old, un-updated email address. Consequently, the company contended it was unaware of the notice and thus unable to submit a response, leading to the final assessment order without its input.
The respondent, the Assessment Unit, argued that earlier notices under Sections 143(2) and 142(1) of the Income Tax Act were successfully delivered to the old email address, even after the update, and the petitioner had responded to them. This, they argued, suggested the company continued to monitor the old email, making its claim of non-receipt of the SCN unconvincing.
