Reassessment based on departmental website data requires verification, disclosure of particulars, and a meaningful opportunity to rebut.

Reassessment based on departmental website information cannot be sustained unless the Assessing Officer verifies the material, seeks the supporting particulars and affords the dealer a meaningful opportunity to rebut the proposed liability. Here, the assessment was completed without the enquiry required in such cases and without furnishing the annexures and particulars sought by the dealer. The Madras HC therefore set aside the higher-tax component of the reassessment and remanded the matter for fresh consideration after disclosure of particulars, receipt of objections and a personal hearing.

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Issues: Whether an assessment proposing higher tax liability, based on information gathered from the departmental website, could be sustained without the Assessing Officer conducting an enquiry and furnishing the dealer with the necessary particulars and an effective opportunity to object.

Analysis: The assessment was reopened on the basis of website-generated information and the dealer sought the supporting annexures and particulars. The impugned assessment was, however, completed without carrying out the enquiry indicated as necessary for such cases and without furnishing full particulars sought by the dealer. In matters of reassessment founded on website information, a mere reference to such information is not enough unless the dealer is afforded a proper opportunity and the Assessing Officer undertakes the required verification before fastening liability.

Conclusion: The assessment to the extent it proposed higher tax liability on the basis of website information could not be sustained and was set aside, with a remand for fresh consideration after furnishing particulars, receiving objections, and granting personal hearing.

Final Conclusion: The challenge succeeded only in part, and the reassessment was reopened for a limited fresh adjudication in accordance with law.

Ratio Decidendi: Where reassessment is founded on information obtained from the departmental website, the Assessing Officer must verify the material and afford the dealer a meaningful opportunity to rebut it before making an adverse tax determination.

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