Natural justice in reassessment requires a fair opportunity to respond before the order is finalised.

A reassessment order was set aside because the Assessing Authority curtailed the time to file objections against the show-cause notice on an erroneous view that limitation was expiring. The Court held that the assessee had been denied a fair and reasonable opportunity to respond, and that the authority should not have rushed the reassessment without allowing effective time to meet the notice. The defect affected the fairness of the procedure and amounted to a breach of natural justice.

---

---

Issues: Whether the reassessment order was liable to be set aside for denial of reasonable opportunity and breach of principles of natural justice.

Analysis: The assessee sought sufficient time to file objections to the show-cause notice, but the Assessing Authority curtailed the time on the footing that limitation was about to expire. The Court found that the stated urgency was based on an erroneous understanding of limitation and that the authority should not have rushed to conclude the reassessment without granting a fair and reasonable opportunity to respond. Since the order was passed without allowing effective time to meet the notice, the defect went to the fairness of the procedure adopted.

Conclusion: The reassessment order was set aside for violation of natural justice and denial of reasonable opportunity to the assessee.

---