Reasonable opportunity of being heard requires a requested personal hearing before enhancement in suo motu revision.

An enhancing revisional assessment cannot be sustained where the assessee has asked for a personal hearing in response to a show cause notice and no hearing is granted. Section 20(4) of the Andhra Pradesh General Sales Tax Act, 1957 and Rule 31(6) of the Andhra Pradesh General Sales Tax Rules, 1957 require a show-cause opportunity and a reasonable opportunity of being heard before an enhancing order is passed. In a suo motu revision affecting substantial tax liability, denial of the requested hearing amounted to breach of natural justice and rendered the revisional order unsustainable.

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Issues: Whether an order revising and enhancing assessment could be sustained when the assessee had requested a personal hearing in response to the show cause notice but no such hearing was granted.

Analysis: Section 20(4) of the Andhra Pradesh General Sales Tax Act, 1957 and Rule 31(6) of the Andhra Pradesh General Sales Tax Rules, 1957 require that no enhancing order be passed without affording the assessee an opportunity to show cause and a reasonable opportunity of being heard. In a case involving substantial tax liability created by suo motu revision, the request for personal hearing formed part of the reasonable opportunity contemplated by the statute and the rules. Denial of the requested hearing amounted to breach of natural justice and vitiated the revisional order.

Conclusion: The revision order was unsustainable for denial of personal hearing and was liable to be set aside.

Ratio Decidendi: Where the statute mandates a reasonable opportunity of being heard before enhancement of assessment, refusal of a requested personal hearing in a suo motu revisional proceeding constitutes a violation of natural justice and invalidates the order.

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