Natural justice in assessment proceedings requires a real hearing and chance to file objections before finalising turnover additions.

Revised assessment orders based on alleged turnover mismatch were set aside because the dealer was denied a personal hearing and a meaningful opportunity to file objections after supply of the cancelled dealers list. The assessing authority proceeded without considering the request for additional time to produce documents, contrary to the departmental circular requiring an opportunity before passing an order. That failure violated the principles of natural justice, and the matter was remitted for fresh consideration after granting the dealer an opportunity to be heard.

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Issues: Whether the revised assessment orders were liable to be set aside for breach of natural justice owing to denial of personal hearing and failure to consider the dealer's request for opportunity to file objections.

Analysis: The assessment turned on alleged mismatch of taxable turnover based on documentary material. The petitioner had specifically sought personal hearing and further time to produce documents after supply of the cancelled dealers list, but the assessing authority proceeded without granting such opportunity. The order also ran contrary to the departmental circular requiring that no order be passed without affording an opportunity to the dealer. In such circumstances, the denial of a meaningful opportunity to explain the position before finalising the assessment amounted to violation of the principles of natural justice.

Conclusion: The impugned assessment orders were set aside and the matter was remitted to the assessing authority for fresh consideration after granting opportunity to the petitioner.

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