Natural justice in tax revision requires supply of relied-upon documents before objections are considered and reassessment proceeds.

Before proceeding with revision of self-assessment under the Tamil Nadu Value Added Tax Act, 2006, the assessing authority was required to furnish the relied-upon material documents to the assessee and then consider the assessee's objections. The writ petitions arose from a proposed revision notice concerning the treatment of imported silk yarn as local exempt yarn. To avoid breach of natural justice, the authority was directed to supply the basic materials forming the basis of the revision and thereafter continue the reassessment or revision process after taking note of any objections already filed in time.

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Issues: Whether the assessing authority was required to furnish the material documents relied upon for revising the assessment and then consider the assessee's objections before proceeding further under the Tamil Nadu Value Added Tax Act, 2006.

Analysis: The writ petitions challenged the proposed revision of self-assessment and the consequential notice. The assessee sought the basic materials relied upon in the revision notice, including the documents said to support the allegation that imported silk yarn had been treated as local exempt yarn, and also sought an opportunity to present objections. In view of the request and the need to avoid violation of natural justice, the authority was directed to furnish the material documents relied upon for the revision and thereafter proceed after taking note of the objections already filed, if filed in time.

Conclusion: The respondent was directed to supply the relied-upon materials and then continue the reassessment/revision process after considering the assessee's objections.

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