Natural justice and reassignment of assessment work upheld where no prejudice was shown and no prior hearing was required.

Transfer and assignment of assessment proceedings within the same city, made as part of administrative allocation of work, did not require prior notice or recorded reasons where no civil or prejudicial consequence to the dealer was shown. The Court held that natural justice applies to administrative action only when such consequences are demonstrated, and appealability of the order did not by itself create a duty to give reasons. The validating provision in the Bombay Sales Tax Act, 1953 was construed as validating jurisdiction and acts done under that jurisdiction, while not barring every challenge in all situations. The continuation provision in the Bombay Sales Tax Act, 1959 kept the earlier law applicable to the relevant assessment period, and the assignment was upheld.

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Issues: Whether the transfer and assignment of the assessment proceedings to the Sales Tax Officer, Enforcement Branch, was invalid for want of reasons and for lack of prior hearing, and whether the validating provision preserved a challenge based on natural justice.

Analysis: The transfer was made within the same city and in the course of administrative allocation of assessment work. The Court held that such a transfer did not, on the facts, cause any demonstrated hardship or adverse consequence to the dealer so as to attract a mandatory hearing requirement. The principles of natural justice apply to administrative action only where civil or prejudicial consequences are shown, and the mere fact that the order was appealable did not make it necessary to record reasons. The validating provision in the Bombay Sales Tax Act, 1953 was construed as validating the jurisdiction and prior acts done in exercise of that jurisdiction, but not as excluding every other challenge in all cases. The continuation provision in the Bombay Sales Tax Act, 1959 kept the earlier law applicable to the assessment period in question.

Conclusion: The order of assignment was not invalid for absence of notice or reasons, and the question referred was answered against the assessee.

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