Quasi-judicial property-tax assessment must disclose valuation basis and be decided by the same officer who hears objections.

A quasi-judicial property-tax assessment under section 126 requires a meaningful show-cause notice before enhancement of rateable value, and fairness demands disclosure of the material basis for the proposed figure when the assessee seeks particulars. A bare notice stating only the proposed increase is insufficient to enable an effective reply. The decision also confirms that where oral objections are heard in a quasi-judicial proceeding, the same officer who hears them must decide the matter; a different officer deciding after another has heard the party undermines natural justice. The impugned assessment was set aside and the matter remitted for fresh assessment in accordance with law.

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Issues: (i) Whether a notice proposing enhancement of rateable value under section 126 was invalid for not disclosing the basis of the proposed figure when the assessee sought such particulars. (ii) Whether the assessment order was vitiated because the objections were heard by one officer and decided by another in a quasi-judicial proceeding.

Issue (i): Whether a notice proposing enhancement of rateable value under section 126 was invalid for not disclosing the basis of the proposed figure when the assessee sought such particulars.

Analysis: Section 126 requires a mandatory notice and consideration of objections before amendment of the assessment list. A notice proposing a substantial increase in rateable value must be effective and meaningful, so that the assessee can meet the case set up against it. Where the assessee specifically asks for the basis of the proposed enhancement, fairness requires disclosure of the material on which the proposed figure has been worked out. A bare statement of the reason, without the foundational basis for the valuation, does not adequately enable a proper response.

Conclusion: The notice could not be treated as invalid outright, but the Corporation was directed to supply the basis of the proposed enhancement to the petitioner.

Issue (ii): Whether the assessment order was vitiated because the objections were heard by one officer and decided by another in a quasi-judicial proceeding.

Analysis: The assessment under the Act is a quasi-judicial function. Where oral hearing is afforded and the statute contemplates consideration of objections, the hearing is not an empty formality. The officer who hears the party must also decide the matter, because oral hearing serves a real adjudicatory purpose and can affect the appreciation of submissions. A decision by a different officer after another officer has heard the party undermines the efficacy of the hearing and violates basic fairness.

Conclusion: The assessment order was vitiated and could not be sustained.

Final Conclusion: The impugned assessment was set aside and the matter was remitted for fresh assessment in accordance with law, with disclosure of the basis of the proposed revision and adherence to proper quasi-judicial procedure.

Ratio Decidendi: In a quasi-judicial property-tax assessment, a show-cause notice enhancing rateable value must disclose the basis of the proposed figure when demanded, and the authority that hears the objections must itself decide them.

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