JUDGMENT 1. In this Writ Petition the petitioner has challenged the Assessment Order No.51310 dt.30.03.2020 read with Rectification Order A.O.No.53991 dt.07.04.2020 passed by the 1st respondent for the Assessment Year 2013-14 under the Telangana Tax on Entry of Goods into Local Areas Act, 2001 (for short, 'the Act'). 2. The petitioner is a registered dealer under the Central Sales Tax Act, 1956 and the Telangana VAT Act, 2005 on the rolls of the 2nd respondent. 3. The 1st respondent issued Pre-Assessment show-cause notice dt.16.03.2019 for the Assessment Year 2013-14 proposing to impose tax of Rs.81,33,422/- under the above Act on the purchases made by the petitioner during the said Assessment Year on Electrical Goods (Electrical Motors And Oil Engines) from registered dealers in their States against 'C' Forms for the purpose of utilizing the same as primary inputs imperative for the petitioners manufacturing process. 4. The said show-cause notice was served on the petitioner one year later on 20.03.2020 and time of only seven (07) days was granted to the petitioner to file objections / reply thereto. 5. On account of COVID-19 pandemic there was a lockdown declared by the Government of Telangana and the Government of India. So the petitioner sent an e-mail dt.24.03.2020 to the 1st respondent informing that in view of the lockdown imposed by the said Governments, both its Head Office in Mumbai and local office in Telangana were closed and requested the 1st respondent to grant further time till the lockdown is lifted and also sought for an opportunity of personal hearing. 6. Without referring to the e-mail sent by the petitioner and without waiting for the lifting of lockdown and denying an opportunity of personal hearing sought by the petitioner, the 1st respondent passed the impugned Assessment Order No.51310 dt.30.03.2020 confirming the tax proposed in the show-cause notice on the ground that petitioner did not file reply and also did not seek any adjournment. 7. The petitioner sent e-mails dt.31.03.2020 and 01.04.2020 protesting that the passing of the said Assessment Order during the lockdown period was in violation of principles of natural justice. The petitioner also contended that the 1st respondent had wrongly imposed tax of Rs.8,13,34,222/- though the tax proposed was only Rs.81,33,422/- and the tax imposed is more than turnover and requested for rectification. 8. The petitioner also contended that the 1st respondent had wrongly imposed tax of Rs.8,13,34,222/- though the tax proposed was only Rs.81,33,422/- and the tax imposed is more than turnover and requested for rectification. 8. Thereafter, the 1st respondent passed the Rectification Order A.O.No.53991 dt.07.04.2020 rectifying the tax imposed as Rs.81,33,422/- instead of Rs.8,13,34,222/-. 9. In the said proceedings, the 1st respondent admitted that he had received the adjournment e-mail dt.24.03.2020 sent by the petitioner and stated that it was not noticed by him. He also admitted that when contacted over phone, the petitioner's authorized representative had informed about the petitioners inability to file a reply due to the lockdown. 10. The petitioner therefore contends that knowing fully well the impossibility on it's part to file objections / reply to the pre-Assessment show-cause notice, the 1st respondent had passed the impugned assessment order and the rectification order and that there has been a gross violation of principles of natural justice. 11. He also contended that the Assessing Authority should have afforded an opportunity of personal hearing to him when such a request was made by him and that he cannot refuse it. The counsel for petitioner placed reliance on the following decisions, viz., S.S. Enterprises, Hyderabad vs. C.T.O.,2010 51 STC 133 (A.P.) Kirby Building Systems India Ltd. vs. Dy. Commissioner (C.T.),2012 54 APSTJ 44 (A.P.) S. Lalaiah & Co. vs. The Dy. Commissioner (C.T.),2007 45 APSTJ 136 (A.P.) and Swami Devi Dayal Hospital and Dental College vs. Union of India, (2013) 10 Scale 608 (S.C.). 12. The counsel for petitioner reiterated the above contentions and sought for setting aside of the impugned order on the ground of violation of principles of natural justice. 13. Sri J. Anil Kumar, learned Special Counsel for Commercial Taxes, appearing for respondents, does not dispute that in the Rectification Order dt.07.04.2020, the 1st respondent admitted that he had received the adjournment e-mail letter dt.24.03.2020 sent by the petitioners seeking adjournment and also the fact that when contacted over phone, the petitioner's authorized signatory specifically informed him of the difficulty to file a reply to the show-cause notice dt.16.03.2019 on account of lockdown of business. 14. 14. When there is a severe restriction imposed by the State in the nature of lockdown on account of COVID-19 pandemic it is unreasonable on the part of the 1st respondent to inform the petitioner to file a response to the show-cause notice dt.16.03.2019 served on 20.3.2020, within the period of seven (07) days. The 1st respondent ought not to have denied the petitioner reasonable time to file objections to the show-cause notice and also a personal hearing since the same was specifically sought by the petitioner in the e-mail dt.24.03.2020. 15. The learned Government Pleader does not dispute that in the decisions quoted by the counsel for petitioner, it was held that the Assessing Authority cannot deny opportunity of personal hearing when such a specific request was made by the dealer and that denial of such an opportunity would vitiate the order passed by the 1st respondent. The Government Pleader, on instructions also stated that the impugned order be set aside and the matter remanded to the 1st respondent for fresh consideration. 16. In this view of the matter, the Writ Petition is allowed; the impugned Assessment Order No.51310 dt.30.03.2020 and the Rectification Order A.O.53991 DT.07.04.2020 passed by the 1st respondent are both set aside; and the matter is remitted to the 1st respondent to pass a fresh order in accordance with law within three (03) months. 17. The petitioner is granted six (06) weeks time from the date of receipt of copy of the order to file a reply along with supporting documents which shall be considered by the 1st respondent, and the 1st respondent shall also provide a personal hearing to the petitioner before passing of the final order in the matter. 18. Accordingly, the Writ Petition is allowed as above. No order as to costs. 19. As a sequel, miscellaneous petitions pending if any in this Writ Petition, shall stand closed.