Income Tax Assessment Order Quashed For Stating No Reply Was Received When Taxpayer Had Filed Detailed Response With 14 Documents: Karnataka HC [Read Order]

In a recent ruling, the High Court of Karnataka quashed a GST assessment order after finding that the Adjudicating Authority had passed the order claiming the assessee had not filed any reply, despite the assessee submitting a detailed response with 14 annexures.

Blackfish Technologies Private Limited, the petitioner had challenged the Order-in-Original dated 15.12.2025 and the subsequent demand order (DRC-07). The case arose from a ShowCause Notice (DRC-01) received by the petitioner on 10.06.2025. The petitioner's counsel submitted that a detailed reply was emailed to the department on 02.07.2025 and subsequently uploaded to the GST portal on 02.08.2025.

However, the Adjudicating Authority, in the impugned order, stated: "in response to DRC-01 dated 10.06.2025, notice the Tax Payer has not filed any reply nor discharged the applicable liability along with the interest and penalty."

The Court perused the documents placed on record, including the email printouts and the portal acknowledgment, which confirmed that a detailed reply accompanied by 14 documents had indeed been furnished.

"Despite which respondent No.1 has stated that there is no reply received, which is contrary to the records. The same violates the principle of natural justice," JusticeSuraj Govindaraj observed.

Finding that the order was passed without considering the submissions made by the assessee, the High Court quashed the impugned orders. The matter was remitted to the Adjudicating Authority for fresh consideration. The Court directed the authority to consider the reply and documents already filed and granted the petitioner a personal hearing, scheduling the appearance for 17.06.2026.

Support our journalism by subscribing to Taxscan premium. Follow us on Telegram for quick updates