Granting merely three days to respond to a show cause notice violates principles of natural justice.

The Petitioner, a private limited company, filed its income tax return for Assessment Year 2024-25. The case was selected for scrutiny

On March 8, 2026 (a Sunday), the Respondent issued a Show Cause Notice (SCN) requiring a response by March 11, 2026—providing only a three-day window

The Petitioner filed a grievance on March 16, 2026, requesting an adjournment and a video conference hearing

Ignoring this request and the filed response, the Respondent passed the impugned assessment order under Section 143(3) read with Section 144B of the Income Tax Act on March 17, 2026

The court applied the fundamental principles of natural justice, specifically the requirement of providing a "reasonable opportunity" to be heard.

It relied on the settled legal principle that a notice period of less than seven days is generally considered insufficient for a meaningful response

The court followed the precedent set in Sanjay Harichand Chugh v. Assessment Unit (2026) regarding the inadequacy of short notice periods

procedural mandates under Section 144B of the Income Tax Act, 1961, which govern the Faceless Assessment Scheme

The court found that the Assessing Officer (AO) acted in clear violation of natural justice by granting only three days to respond to an SCN issued on a non-working day (Sunday)

The court reasoned that such a brief timeline is "grossly insufficient" to allow a taxpayer to file an effective reply

the court noted that the Petitioner had proactively filed a grievance and requested a video conference hearing on March 16, 2026, yet the AO proceeded to pass the final order the very next day without addressing the grievance or granting the hearing

The court rejected the Respondent’s technical argument that the grievance was misdirected to the jurisdictional AO rather than the Faceless AO, emphasizing that the lack of reasonable opportunity was the primary flaw

The High Court quashed and set aside the assessment order and remanded the matter to the Assessing Officer. The Court directed the AO to provide the Petitioner an adequate opportunity for a written reply and a personal hearing (if permissible by law) and to pass a fresh order within twelve weeks