Personal hearing in tax revision is not automatic, but disputed facts can make it necessary before assessment enhancement.

In revision under section 20 of the Andhra Pradesh General Sales Tax Act, the revisional authority may examine legality or propriety of subordinate orders and enhance assessment only after giving the assessee an opportunity to show cause. A personal hearing is not an automatic requirement in every quasi-judicial revision, but it becomes necessary where the material facts are disputed and fairness requires oral explanation before an adverse enhancement. On the facts described, the assessee's explanation raised a contested factual issue that was not addressed by the revisional authority, so the absence of a personal hearing vitiated the revisional order and it was liable to be set aside.

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Issues: Whether, in revision proceedings under section 20 of the Andhra Pradesh General Sales Tax Act, the assessee was entitled as of right to a personal hearing before enhancement of assessment, and whether denial of such hearing vitiated the revisional order on the facts of the case.

Analysis: Section 20 empowers the revisional authority to examine the legality or propriety of subordinate orders and to enhance assessment only after giving the assessee an opportunity to show cause. The provision does not in terms require a personal hearing in every case, and a personal hearing is not an automatic ingredient of natural justice in all quasi-judicial proceedings. However, whether such hearing is necessary depends on the facts of each case. Here, the assessee's explanation raised a disputed factual position as to the nature of the purchase and whether the turnover was a second sale, but the revisional authority proceeded on a different factual premise without dealing with that explanation. In those circumstances, the matter required a personal hearing before the revision could be disposed of.

Conclusion: The assessee was not entitled to a personal hearing as an absolute right in every revision under section 20, but on the facts of this case the revisional order was vitiated for want of a personal hearing and was liable to be set aside.

Ratio Decidendi: In quasi-judicial revision proceedings, personal hearing is not invariably mandatory as a matter of law, but it must be afforded where the facts are disputed and fairness requires oral hearing before an adverse enhancement is made.

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