Natural justice in reassessment demands a real opportunity of hearing before liability is confirmed and notices are issued.

Reassessment orders passed without considering a taxpayer's request for personal hearing and without giving a proper opportunity to file objections and supporting material are unsustainable for breach of natural justice. The absence of an effective hearing and the failure to follow mandatory procedural requirements deprived the taxpayer of a fair chance to contest the proposed liability, so the reassessment and consequential demand notices were set aside. The matter was remitted for fresh consideration after affording a reasonable opportunity of hearing.

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Issues: Whether the reassessment orders and consequential demand notices were liable to be set aside for want of reasonable opportunity of personal hearing and violation of the principles of natural justice.

Analysis: The reassessment orders were passed without considering the petitioner's request for personal hearing and without giving sufficient opportunity to place objections and material in support of its defence. The absence of a proper enquiry and the failure to comply with the mandatory procedural requirements deprived the petitioner of an effective chance to contest the proposed liability. In such circumstances, the impugned reassessment could not be sustained.

Conclusion: The reassessment orders and the consequential demand notices were rightly set aside and the matter was remitted for fresh consideration after affording reasonable opportunity to the petitioner.

Ratio Decidendi: A reassessment order made without affording a reasonable opportunity of hearing and in breach of natural justice is unsustainable and may be set aside with a direction for fresh consideration.

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