Natural justice in reassessment notices requires full disclosure of materials relied on, or the notice fails.

A revision show-cause notice proposing reassessment under section 16 of the Tamil Nadu General Sales Tax Act, 1959 must disclose the materials, records, and specific basis relied on so the assessee can meaningfully answer the proposal. Where the notice refers to alleged defects or recovered records, it must supply the relevant particulars and supporting material to enable an effective rebuttal. A bare notice that omits those details denies a reasonable opportunity of objection and fails the requirements of natural justice; the Madras HC therefore held the notice unsustainable and set it aside.

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Issues: Whether a revision show-cause notice proposing reassessment under section 16 of the Tamil Nadu General Sales Tax Act, 1959 could be sustained when it did not disclose the materials and records relied upon and thereby denied the assessee a meaningful opportunity to object.

Analysis: A notice proposing revision of assessment must disclose the basis of the proposed action with sufficient particulars so that the assessee can effectively meet the allegations. Where the notice is founded on alleged defects and recovered records, the affected dealer must be given the relevant details and supporting materials to rebut the case. A bare notice that omits such particulars does not afford reasonable opportunity and fails the requirements of natural justice.

Conclusion: The show-cause notice was unsustainable and was set aside.

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