Natural justice in tax assessment requires correct particulars, disclosure of relied-upon documents, and a meaningful hearing before adverse action.

An assessment or penalty order based on discrepant buyer and transaction particulars is vulnerable where the assessee is not supplied the relied-upon check-post register and bill copies before adverse action is taken. The court found that such defects deprived the assessee of a proper opportunity to meet the allegation of sales suppression and amounted to a breach of natural justice. The impugned order was therefore set aside, and the matter was remanded for reconsideration after furnishing the correct particulars and documents and granting a personal hearing.

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Issues: Whether the impugned assessment and penalty order was liable to be set aside for want of correct particulars, denial of opportunity, and violation of natural justice.

Analysis: The notice and the final order referred to different buyer particulars and different transaction details, and the assessee was not furnished the relevant check-post register or bill copies before the adverse order was passed. In these circumstances, the order was found to have been passed without giving a proper opportunity to meet the allegation of sales suppression and without fair adjudication.

Conclusion: The impugned order was rightly set aside and the matter was directed to be reconsidered after furnishing the correct particulars and documents and after affording personal hearing to the petitioner.

Ratio Decidendi: An assessment or penalty order based on discrepant transaction particulars, passed without supplying relied-upon documents and without affording a meaningful hearing, is liable to be set aside for violation of natural justice.

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