Reasoned scrutiny under section 16D is required before rejecting an assessment challenge for alleged natural justice violations.

Section 16D of the Tamil Nadu General Sales Tax Act requires the Special Committee to scrutinise whether an assessment was made in violation of the Act, the Rules, or natural justice, and to apply its mind to those jurisdictional grounds. A mechanical rejection based only on the assumption that no reply was filed, without considering the assessee's claim that a pre-assessment objection had been submitted and ignored, was held unsustainable. The rejection order was set aside and the matter remitted for fresh, reasoned consideration in accordance with law.

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Issues: Whether the Special Committee, while exercising power under section 16D of the Tamil Nadu General Sales Tax Act, 1959, was justified in rejecting the application without examining whether the assessment order was passed in violation of the Act, the Rules, or the principles of natural justice.

Analysis: Section 16D empowers the Special Committee to scrutinise the assessment record and interfere where the proceeding or order is made in violation of the Act or Rules or without following natural justice. The Committee was required to consider the assessee's specific case that a reply to the pre-assessment notice had been filed and that the objections were not considered. The impugned order, however, proceeded only on the footing that no reply had been filed and did not record any finding on whether there was violation of the statutory provisions or whether the explanation offered by the assessee had been properly examined. Such a cursory approach did not reflect the exercise of the statutory power in the manner contemplated by the provision.

Conclusion: The rejection order was unsustainable and was set aside. The matter was remitted to the Special Committee for fresh consideration of the section 16D application and for passing a detailed order in accordance with law.

Ratio Decidendi: Where a statute confers power to interfere with an assessment made in violation of law or natural justice, the authority must apply its mind to those jurisdictional grounds and cannot reject the application mechanically without recording a reasoned finding.

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