J.M. Steel Traders Vs Assessing Officer (Orissa High Court)
J.M. Steel Traders approached the Orissa High Court challenging an assessment order dated 19 March 2025 under Sections 143(3) and 144B of the Income Tax Act, 1961, for the assessment year 2023-24. The taxpayer alleged that the assessment was conducted in violation of the Standard Operating Procedure (SOP) issued by the Central Board of Direct Taxes (CBDT) for faceless assessments and contended that principles of natural justice were not followed. Specifically, the petitioner argued that the show-cause notice dated 21 February 2025, which required a response by 27 February 2025, did not comply with the period stipulated in clause N.1.3 of the SOP. The petitioner further claimed that the Assessing Officer exceeded the scope of the show-cause notice by adding ₹5,27,55,976 to the income without any notice, rendering the assessment order vitiated.
The Department, represented by the Senior Standing Counsel, submitted that the show-cause notice provided sufficient time for response and that the petitioner had submitted its written reply within the period prescribed. It argued that the petitioner had not raised concerns regarding the notice period before the authority at the time, and therefore, the claim of non-compliance with the SOP did not warrant intervention by the Court. The Department further submitted that whether the Assessing Officer exceeded the terms of the show-cause notice is a matter of fact to be determined on evidence before the Appellate Authority, which is competent to adjudicate the dispute under the Income Tax Act.
