Fairness in tax revision demands disclosure of seller particulars before adverse assessment action is finalised.

Fairness in tax revision proceedings required the assessing authority to disclose the seller names and particulars relied upon in the revision notices. Because the proposed additions were based on cross-verification and alleged non-reporting by identified sellers, withholding those details would deprive the assessee of an effective opportunity to respond. The assessment orders were set aside, and the matter was remitted for fresh consideration after furnishing the seller particulars, receiving a fresh reply, and deciding the issues independently on merits in accordance with law.

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Issues: Whether the assessment orders were liable to be set aside for failure to furnish the names and particulars of the sellers relied upon in the revision notices, and whether the matter required fresh consideration after disclosure of those particulars.

Analysis: The revision notices proceeded on the basis of cross-verification between buyer and seller annexures and alleged that the corresponding sales had not been reported by the sellers. Since the assessing authority had relied on identified sellers as the foundation of the proposed revision, fairness required disclosure of those particulars before final orders were made. Without such information, the assessee would be deprived of an effective opportunity to reply to the proposed additions. The orders were therefore set aside without entering into the merits, and the authority was directed to furnish the seller details, obtain a fresh reply, and decide the matter independently on all issues.

Conclusion: The impugned assessment orders were set aside and the matter was remitted for fresh assessment after furnishing the seller particulars and considering the assessee's reply.

Final Conclusion: The writ petitions succeeded to the extent of remand, with a direction to supply the relevant information and pass fresh orders on merits in accordance with law.

Ratio Decidendi: An assessment founded on undisclosed particulars relied upon by the authority cannot be sustained where denial of those particulars would defeat an effective opportunity of reply and violate fairness in procedure.

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