Natural justice does not require disclosure of internal investigative communications when the relied-on material has already been supplied.

At the show-cause stage, a noticee has no automatic right to obtain internal or inter-departmental investigative communications where the notice rests on disclosed material. The court found that the show-cause notice was based on bank records and information obtained from the petitioner's bankers, and those records had already been supplied. As the refusal concerned only internal correspondence between the investigating agency and the adjudicating authority, and no undisclosed material underpinned the notice, the objection based on natural justice failed. The refusal to furnish the requested internal DRI communications was therefore upheld.

---

---

Issues: Whether the petitioner was entitled, at the show-cause stage, to copies of the Directorate of Revenue Intelligence's internal communications and related documents on the ground of violation of natural justice.

Analysis: The challenge was confined to refusal of copies of internal correspondence between the investigating agency and the adjudicating authority. The show-cause notice was found to be founded on bank records and information obtained from the petitioner's bankers, and those relevant records had already been supplied. The petitioner was not entitled, as of right, to insist on disclosure of internal or inter-departmental communications at the show-cause stage, particularly when the notice was not based on undisclosed material. The cited precedent was held to be distinguishable on facts.

Conclusion: The refusal to supply the requested internal DRI communications did not violate natural justice and was upheld.

Ratio Decidendi: A noticee is not entitled, as a matter of right, to obtain internal or inter-departmental investigative communications at the show-cause stage where the material relied upon for the notice has already been disclosed.

---