Failure to consider a manually submitted reply and absence of personal hearing vitiates assessment order

BOLDROCCHI INDIA PRIVATE
LIMITED
Vs.
THE STATE TAX OFFICER (ST) &
ORS.
W.P.Nos.18923, 18927, 18929, 18959,
18962, 18971 & 18980 of 2025 &
W.M.P.Nos.21204, 21205, 21210,
21211, 21215, 21216, 21244, 21249,
21252, 21254, 21257, 21259, 21264 &
21266, 25770, 25768, 25765, 25759,
25752 & 25755 of 2025

HIGH COURT: Madras
DATED: 26.06.2025

Citation: 2025 taxo.online 1484

Failure to consider a manually submitted reply and absence of personal hearing vitiates assessment order, being in violation of principles of natural justice.

Assessment & rectification orders passed without considering manually filed reply – Violation of natural justice – Respondents submits reply not considered as not uploaded on portal and had no objection to remand – Court held irrespective of mode of filing portal or manual assessing officer duty bound to consider reply and afford hearing

Held: Writ petitions allowed – Orders set aside – Matters remanded for de novo consideration with direction to consider manual reply and provide 14 days advance notice of hearing.

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