Natural justice in assessment revisions requires item-wise consideration of objections, a speaking order, and personal hearing when demanded.

Assessment orders are unsustainable where the assessing authority fails to consider objections item-wise, disposes of them through a brief non-speaking order, and denies a requested personal hearing in a revision proceeding involving disputed facts. The authority must address each objection with reasons and grant a hearing when demanded to satisfy natural justice. On these facts, the orders were set aside for violation of fair procedure.

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Issues: Whether the assessment orders were liable to be set aside for failure to consider the objections item-wise and for denial of personal hearing, thereby violating the principles of natural justice.

Analysis: The objections filed to the pre-revision notices raised specific answers to each proposed addition, but the assessment orders did not deal with them item-wise and were concluded in a brief, non-speaking manner. Where revision of assessment is proposed, the assessing authority is required to consider the dealer's objections, deal with them by a speaking order, and grant a personal hearing when demanded, especially where disputed factual issues arise. The failure to consider the request for personal hearing and the absence of a reasoned disposal of the objections amounted to violation of fair procedure.

Conclusion: The assessment orders were unsustainable and were set aside.

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