Natural justice in tax assessment requires furnishing relied-upon documents before adverse additions are made.

Non-furnishing of relied upon purchase bills and related details vitiated the assessment for breach of natural justice, because the taxpayer was not given a meaningful opportunity to meet the proposed additions under the Tamil Nadu Value Added Tax Act, 2006. Repeated requests for the documents and filed objections showed that the disputed factual particulars were never properly verified before the final assessment was made. The Madras High Court therefore set aside the assessment order and remanded the matter for fresh consideration, directing that the relied upon bills be furnished and that objections and oral hearing be afforded.

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Issues: Whether the assessment order was liable to be set aside for violation of the principles of natural justice on account of non-furnishing of relied upon documents and denial of an effective opportunity to object.

Analysis: The writ petition challenged the assessment under the Tamil Nadu Value Added Tax Act, 2006 on the ground that the petitioner was not supplied full copies of the purchase bills and related details relied upon in the pre-revision proceedings. The record showed repeated requests for the documents, objections filed by the petitioner, and a final assessment made without ensuring that the disputed factual details were properly verified. The absence of full particulars meant that the petitioner did not receive a meaningful opportunity to meet the proposed additions, and the assessment could not be sustained on the footing that adequate opportunity had been given.

Conclusion: The assessment order was set aside and the matter was remanded for fresh consideration after furnishing the relied upon bills and granting opportunity to file objections and be heard.

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