Gudiyatham Muniraj Ashokkumaran Vs ACIT (Madras High Court)
In a recent judgment, the Madras High Court addressed the case of Gudiyatham Muniraj Ashokkumaran versus ACIT, concerning an assessment order for the assessment year 2015-16. The petitioner challenged the order on grounds of natural justice, specifically due to inadequate time granted to respond to a significant addition in income tax.
The petitioner filed their income tax return for the relevant assessment year on 24th March 2018. Subsequently, re-assessment proceedings were initiated under Section 148 of the Income Tax Act. Following this, notices under Section 143(2) and Section 142(1) were issued, requesting clarification and documents related to the return of income. The petitioner responded to these notices on several occasions in early 2024.
The crux of the petitioner’s argument lies in the show cause notice dated 24th March 2024, which demanded an explanation for adding Rs. 79,08,458 to the total income. The petitioner was given only two days to respond to this notice, a timeline they deemed insufficient and unfair.
The High Court, upon reviewing the sequence of events and arguments presented, found merit in the petitioner’s contention. It emphasized that natural justice demands a reasonable opportunity to be heard before a decision affecting one’s rights is made. The court noted that the brief period provided in the show cause notice did not meet this standard.
