Natural justice in assessment proceedings requires personal hearing and meaningful objections; order quashed and matter remanded.

An assessment order passed without a personal hearing and without a meaningful opportunity to raise objections was held to be vitiated by breach of natural justice. The court noted that the reply to the pre-revision notice did not amount to an effective merits-based response, and the authority proceeded to finalise the revision without adequate participation by the assessee. The existence of an alternate remedy was not treated as a bar on these facts. The assessment order was quashed and the matter was remanded for fresh consideration after granting adequate opportunity.

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Issues: Whether the assessment order was liable to be quashed for violation of principles of natural justice, including denial of personal hearing and opportunity to raise objections, and whether the matter should be remanded for fresh consideration.

Analysis: The petitioner had not been granted a personal hearing before the assessment order was passed. The reply to the pre-revision notice did not contain a merits-based explanation, and the authority proceeded without affording adequate opportunity to contest the proposed revision. In these circumstances, the denial of hearing and the failure to permit effective objections amounted to breach of natural justice. The existence of an alternate remedy was not treated as a bar in the facts of the case.

Conclusion: The assessment order was quashed and the matter was remanded to the respondent for fresh consideration after granting adequate opportunity to the petitioner.

Ratio Decidendi: An assessment order passed without affording personal hearing and a meaningful opportunity to file objections is vitiated by breach of natural justice and can be set aside with a remand for de novo consideration.

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