Tamil Nadu Power Distribution Corporation Ltd Vs JCIT (Madras High Court)
Madras High Court held that non-granting sufficient time to the petitioner for furnishing reply results into lack of opportunities being provided to the petitioner. Accordingly, order passed thereon is liable to be set aside.
Facts- These writ petitions have been filed by the petitioner challenging the impugned assessment orders dated 29.03.2025, passed by the 1st respondent, relating to the Assessment Years 2018-2019 and 2019-2020.
Petitioner mainly contested that the 1st respondent issued show cause notice on 24.03.2025, directing the petitioner to file their reply to all the queries raised in the show cause notice on or before 26.03.2025. Since the petitioner was not in a position to file their reply on time, they filed their reply only on 28.03.2025, pointing that two days time granted for furnishing the reply is totally inadequate and requested to grant at least four weeks time to enable the petitioner to give a more detailed reply. On the same day, the respondent issued another show cause notice directing the petitioner to file reply by 29.03.2025 (5 PM). Without considering the request made by the petitioner on 28.03.2025, the 1st respondent passed the impugned assessment order on 29.03.2025.
