Natural justice in assessment proceedings requires a meaningful hearing and reasoned order before finalisation.

Assessment orders were found vulnerable where the authority relied on inspection materials, treated the dealer as having admitted discrepancies without support from the recorded statement, and failed to deal meaningfully with objections seeking reconciliation and a personal hearing. The High Court noted that fair procedure required examination of the transaction details, disclosure of the relevant materials, and an effective opportunity to explain before finalisation. Because the reasoning was vague and mechanical, the adjudication was held contrary to natural justice. The assessment orders were set aside and the matters remitted for fresh consideration, with personal hearing and a speaking order to be passed in accordance with law.

---

---

Issues: Whether the assessment orders were liable to be set aside for breach of natural justice in the handling of the objections and request for personal hearing.

Analysis: The assessment was based on inspection materials and the authority proceeded on the footing that the dealer had admitted the discrepancies, though the recorded statement did not support such an admission. The objections disclosed a request to reconcile the alleged purchase omission and to be heard before finalisation. The authority was expected to examine the transaction details and provide a meaningful opportunity before completing the assessment, but the orders were made on vague and mechanical reasoning. The resulting adjudication was found to be contrary to fair procedure.

Conclusion: The assessment orders were unsustainable and were set aside, with the matters remitted for fresh consideration after affording personal hearing, supplying required details, and passing a speaking order in accordance with law.

---