Natural justice in sales tax assessments requires notice, hearing, and proper consideration of supporting exemption documents before demand.

An assessment completed without issuing a show-cause notice or allowing objections was vitiated for breach of natural justice. The authority also refused relief without examining Form C declarations and export or transit sale documents, even though the departmental circular permitted acceptance of belated statutory forms and revision of assessments. The assessment and consequential demand were therefore set aside, and the matter was remanded for fresh consideration after personal hearing and examination of the relevant documents.

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Issues: Whether the assessment order and consequential demand were liable to be quashed for violation of principles of natural justice and for non-consideration of Form C declarations and export and transit sale documents.

Analysis: The assessment was completed without issuing a show-cause notice or affording an opportunity to file objections. The order also proceeded to apply a higher rate of tax to transactions not covered by Form C and rejected the exemption claim without calling for or examining the export and transit sale documents. The circular issued by the Commissioner required assessing officers to accept belated statutory forms and to revise assessments under Section 55 of the Tamil Nadu General Sales Tax Act, 1959. On that basis, the belated production of Form C declarations could not be treated as the sole ground to deny relief, and the relevant documents had to be considered by the assessing authority.

Conclusion: The impugned assessment and consequential demand were set aside and the matter was remanded for fresh consideration after granting personal hearing and permitting production and examination of the relevant documents.

Final Conclusion: The assessee succeeded in obtaining quashing of the adverse assessment and a fresh adjudication before the assessing authority.

Ratio Decidendi: An assessment made without notice and without considering relevant supporting documents is vitiated by violation of natural justice and must be remitted for fresh decision, particularly where the departmental circular permits acceptance of belated statutory forms and revision of the assessment.

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