Natural justice and voluntary documents: a tribunal may draw its own conclusions without separately confronting the party with inferences from the record.

A quasi-judicial authority does not violate natural justice by drawing conclusions from a balance sheet or other material voluntarily produced by a party, and it need not separately confront the party with every discrepancy noticed in that document. The challenge based on breach of natural justice therefore failed. Allegations of perversity were left open because rectification petitions on the same factual issues were already pending before the Tribunal, which was directed to decide those petitions on merits.

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Issues: Whether the Tribunal violated the principles of natural justice by relying upon the balance sheet and other material that had been voluntarily relied upon by the assessee.

Analysis: The revision petitioner itself invited the Tribunal's attention to the balance sheet. Once a party produces a document before a quasi-judicial authority, the authority is entitled to draw its own conclusions from it. There is no rule of natural justice requiring the Tribunal to confront the party with the discrepancies noticed by it in the document so produced. The challenge based on violation of natural justice therefore failed. Other grounds relating to perversity were left open, as rectification petitions on the same factual issues were already pending before the Tribunal.

Conclusion: The challenge based on breach of natural justice was rejected and answered against the assessee.

Final Conclusion: The revision was disposed of by declining to interfere on the natural justice issue and directing the Tribunal to decide the pending rectification petitions on merits.

Ratio Decidendi: A quasi-judicial authority does not breach natural justice by drawing conclusions from a document voluntarily produced by a party, without separately confronting that party with the inferences drawn from it.

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