Natural justice in valuation disputes requires disclosure of relied-upon cost reports before adjudication and fresh hearing on remand.

An adjudication based on undisclosed cost reports relied upon to determine assessable value cannot be sustained where the assessee was not supplied those materials before the order was passed. Reliance on reports received after the personal hearing, without giving the affected party an opportunity to respond, breaches natural justice and undermines the fairness of the demand proceedings. The proper course in such circumstances is to set aside the defective order and remand the matter for fresh adjudication after disclosure of the relied-upon reports and a further opportunity of hearing.

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Issues: Whether the impugned order was liable to be set aside for breach of principles of natural justice on account of non-supply of the Assistant Director (Cost) reports relied upon for determining assessable value.

Analysis: The order was founded on cost reports dated after the date of personal hearing, yet the appellant was not supplied copies of those reports before the order was passed. Since the adjudication relied on material not disclosed to the appellant, the appellant was denied an effective opportunity to meet the basis of the demand. In these circumstances, the defect went to the fairness of the adjudication itself.

Conclusion: The impugned order was rightly set aside and the matter remanded for fresh adjudication after supplying the relied-upon reports and granting an opportunity of hearing.

Final Conclusion: The dispute was not finally decided on merits, and the adjudicating authority must reconsider it afresh after curing the procedural defect.

Ratio Decidendi: An adjudication cannot be sustained when it relies on undisclosed material and thereby denies the affected party a reasonable opportunity to respond; such violation of natural justice warrants remand for fresh decision.

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