Court sets aside assessment orders due to procedural unfairness, lack of personal hearing, and reliance on external reports.

The court found that the assessment orders in the case were untenable due to the Assessing Officer's failure to consider the petitioner's objections, violation of natural justice by not granting a personal hearing, and incorrect reliance on external reports. Emphasizing the importance of procedural fairness and independent assessment, the court set aside the orders and directed a fresh consideration with a directive for a personal hearing, stressing the Assessing Officer's duty to assess independently without external influence.

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Issues:
Challenge to assessment orders based on abdication of powers of Assessing Officer, violation of natural justice, and non-application of mind.

Detailed Analysis:

Assessment Years 2012-13 to 2014-15:
- Petitioner engaged in gold, silver, diamond trading.
- Show cause notices issued for defects in returns, proposed penalty.
- Petitioner's reply sought personal hearing, submitted explanation.
- Acknowledgment proves receipt of explanation by respondent.
- Orders passed without considering petitioner's objections, incorrect statement by respondent.
- Orders challenged in Writ Petitions 19007 to 19009 found untenable.

Assessment Years 2011-12 to 2014-15:
- Pre-assessment notices issued based on Enforcement Wing's report.
- Petitioner disputed pre-prepared statement, requested correction.
- Petitioner's objections not considered, no personal hearing granted.
- Assessment orders passed without independent scrutiny, influenced by report.
- Respondent's duty to assess independently, not influenced by external factors.
- Observations by respondent erroneous, not in line with legal principles.

Legal Precedents and Principles:
- Assessing Officer's duty to assess independently, quasi-judicial nature of proceedings.
- Importance of personal hearing when adverse findings proposed.
- Necessity for Assessing Officer to consider dealer's objections independently.
- Error in not granting personal hearing, incorrect reliance on external reports.
- Orders set aside, matters remitted for fresh consideration with personal hearing.
- Respondent directed to decide independently without influence from external reports.

This judgment highlights the importance of procedural fairness, independent assessment by the Assessing Officer, and the need for personal hearings in tax assessment matters. The court emphasized the duty of the Assessing Officer to consider objections, conduct assessments independently, and not be unduly influenced by external reports. The judgment sets aside the impugned orders and remits the matters for fresh consideration with a directive to grant a personal hearing to the petitioner.

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