Natural justice requires a fresh hearing after a corrigendum to the show cause notice before final adjudication.

A corrigendum to the show cause notice was issued, but the assessee was not given a further opportunity to file a reply or be personally heard before the final adjudication. That procedural omission was treated as a serious breach of natural justice, because the amended notice could not be acted upon without giving the affected party a meaningful chance to respond. The adjudication was therefore set aside and the matter remanded for de novo adjudication after affording adequate opportunity to reply and be heard.

---

---

Issues: Whether the adjudication was vitiated for want of opportunity to reply and be personally heard after issuance of the corrigendum to the show cause notice, and whether the matter should be remanded for fresh adjudication.

Analysis: The corrigendum introduced amendments to the show cause notice, but no further opportunity was afforded to the assessee to file a reply or to be heard in person before the final order was passed. This omission was treated as a serious procedural lapse amounting to violation of natural justice. In such circumstances, the proper course was to set aside the adjudication and direct a fresh decision after granting adequate opportunity.

Conclusion: The adjudication was held to be vitiated for breach of natural justice, and the matter was remanded for de novo adjudication after giving the assessee an opportunity to reply and be heard.

---