Justice D. Bharatha Chakravarthy observed that the order contained references to the petitioner’s reply. The Court noted that the petitioner had submitted a written response but chose not to appear for the personal

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Mere Non-Acceptance of Reply Does Not Amount to Natural Justice Violation: Madras HC Directs to Avail Appellate Remedy [Read Order]
The Court noted that the petitioner had submitted a written response but chose not to appear for the personal hearing. Therefore, it held that a rejection of a reply does not equate to a violation of natural justice.
By –  Navasree A.M |
9 Mar 2026 12:49 PM

The Madurai Bench of the Madras High Court held that mere non-acceptance of a taxpayer’s reply by the assessing authority does not constitute a violation of the principles of natural justice, especially when the reply has been considered and a statutory appellate remedy is available.

The petitioner, M.G.P. Store approached the High Court to quash an assessment order dated 28 November 2025.

The petitioner contended that although a reply had been submitted, the impugned order failed to properly deal with their contentions.

It was argued that the reply was not even enumerated in the reference column and was rejected without adequate reasoning.

The petitioner alleged the authority merely stated the reply was “not accepted” and passed the order because the taxpayer skipped the personal hearing, reflecting a non-application of mind.

On the other hand, the State contended that the order clearly indicated the reply had been verified and considered. The government submitted that the authority’s decision not to accept the explanation does not imply the reply was ignored.

It was further argued that the GST Act provides an effective appellate mechanism, and the petitioner should pursue that rather than invoking writ jurisdiction.

Justice D. Bharatha Chakravarthy observed that the order contained references to the petitioner’s reply.

The Court noted that the petitioner had submitted a written response but chose not to appear for the personal hearing. Therefore, it held that a rejection of a reply does not equate to a violation of natural justice.

Therefore the high court refused to quash the assessment order and directed to take the alternative remedy within one week leaving merits of the matter open.

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Navasree A.M
Navasree A M, B.B.A., LL.B. (Hons), a lawyer with over 2.5 years of experience as a researcher and content writer at Taxscan, specializing in Indirect Taxes and Corporate Laws.

Madras High Court
Writ Jurisdiction

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Penalty for Non-Compliance of Notices not Leviable where Assessment Completed u/s 143 based on Information Furnished: ITAT [Read Order]
ITAT Indore holds that penalty for non-compliance cannot survive when assessee later complies and assessment is completed under Section 143(3).
By –  Solony Padhi |
9 Mar 2026 4:35 PM

The Income Tax Appellate Tribunal (ITAT), Indore Bench held that the penalty imposed for the alleged non-compliance of the statutory notices cannot be sustained if the assessee complies with the same and the assessment is completed under Section 143(3) of the Income Tax Act, 1961.

The assessee Ujjain Dugdh Sangh (Sah) Maryadit has filed an appeal before the tribunal against the order of the Commissioner of Income Tax.

The National Faceless Appeal Centre (NFAC),who had passed the order imposing a penalty on the assessee. The assessee had failed to comply with the notices issued under Section 142(1) of the Act during the assessment proceeding for Assessment Year 2020-21 for a penalty of ₹30,000 under Section 272A(1)(d).

The assessee had stated that although there was an initial delay in responding to certain notices, the necessary information was furnished subsequently before the AO.

The contention was that the assessment was actually completed under Section 143(3) of the Act, taking into consideration the information furnished by the assessee. Therefore, there was no justification for imposing a penalty for non-compliance.

In contrast, it was contended by the Revenue
[09/03, 16:37] Meta AI: மதுரை பெஞ்ச், மெட்ராஸ் உயர்நீதிமன்றம்: வரி செலுத்துநர் பதிலை “ஏற்கவில்லை” என்று மட்டும் சொல்வது இயற்கை நீதி மீறல் இல்லை. பதில் பரிசீலிக்கப்பட்டது, தனிப்பட்ட விசாரணைக்கு வரவில்லை; மேல்முறையீட்டு வழி உள்ளதால் ரிட் தள்ளுபடி, ஒரு வாரத்துக்குள் மேல்முறையீடு செய்யச் சொல்லி விட்டது.【Navasree A.M, 9 Mar 2026】
[09/03, 16:37] Meta AI: Madras HC (Madurai Bench) held that simply rejecting a taxpayer’s reply isn’t a breach of natural justice if it was considered—petitioner skipped the personal hearing, and an appellate remedy exists. The writ was dismissed; court told them to appeal within a week, leaving merits open.