Effective opportunity of hearing in assessment proceedings requires fair notice, meaningful time to reply, and consideration of adjournment requests.

Revised assessment orders were challenged for denial of an effective hearing, as the notices allowed only three days for objection and the assessee had sought adjournment to file a reply and produce books of account. The court found that passing the orders in undue haste without a meaningful opportunity to be heard failed the requirements of fair procedure and could not be sustained on judicial review. The orders were therefore set aside and the matter remanded for fresh assessment after granting an effective opportunity to produce records and be heard.

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Issues: Whether the revised assessment orders were liable to be set aside for denial of an effective opportunity of hearing and whether the matter required fresh consideration by the assessing authority.

Analysis: The assessment notices afforded only three days for objection, and the record itself showed that the assessee had sought adjournment to file a reply and produce books of account. The orders were passed in undue haste without granting a meaningful opportunity to be heard. Such a course did not satisfy the requirements of fair procedure and could not be sustained on judicial review.

Conclusion: The revised assessment orders were set aside and the matter was remanded to the assessing authority for fresh assessment after giving an effective opportunity to produce records and be heard.

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