Natural justice bars reversal of input tax credit on invoice mismatch without disclosure of materials and a fair hearing.

Assessment orders reversing input tax credit on alleged invoice-wise mismatch in cross-verification were held unsustainable because the dealer was not furnished the relevant dealer details, the documents sought, or a personal hearing. The Court found that the objections, including the claim that the purchase bills satisfied Rule 10(2) of the Tamil Nadu Value Added Tax Rules, 2007, were not fully considered, and that the matter had been concluded without a fair opportunity to reconcile transactions. The assessments were therefore set aside and the matters remanded for fresh consideration, with directions to supply all dealer details, receive objections, grant personal hearing, and pass a speaking order on merits in accordance with law.

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Issues: Whether the assessment orders relating to cross verification of invoice-wise mismatch and reversal of input tax credit were sustainable when the dealer was not furnished the relevant dealer details, the documents sought, or an opportunity of personal hearing.

Analysis: The dispute concerned reversal of input tax credit on the basis of mismatch shown by cross verification of purchases with sellers' returns. The dealer had asked for complete particulars and asserted that the purchase bills satisfied the requirements under Rule 10(2) of the Tamil Nadu Value Added Tax Rules, 2007. The assessment orders did not deal with the entirety of the objections, did not furnish the particulars sought from the departmental website, and did not afford personal hearing. In the absence of those particulars and a fair opportunity to reconcile the transactions, the assessments were found to have been completed in breach of the principles of natural justice.

Conclusion: The finding relating to cross verification and invoice-wise mismatch could not be sustained and was set aside.

Final Conclusion: The matters were remanded to the respondent for fresh consideration after furnishing all dealer details, receiving objections, granting personal hearing, and passing a speaking order on merits in accordance with law.

Ratio Decidendi: An assessment based on alleged invoice mismatch cannot be sustained where the assessee is denied the material particulars relied upon and a fair opportunity of hearing, since such disposal violates the principles of natural justice.

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