Independent consideration in assessment matters required before finalising orders; reliance on inspection reports alone is insufficient.

Assessment orders can be invalid where the Assessing Officer does not independently consider the assessee's objections and supporting records, but relies only on an inspection report. The Court noted that the officer should have called for the relevant books of account and documents, applied an independent mind to the response, and afforded a personal hearing before finalising the assessment. Reliance on the inspection team's proposal could support issuance of notice, but not replace proper adjudication on the merits of the dealer's explanation. The impugned assessments were set aside and the matter was remanded for fresh consideration.

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Issues: Whether the assessment orders were liable to be set aside for failure to properly consider the assessee's objections and for acting solely on the inspection report, and whether the matter required remand for fresh assessment.

Analysis: The assessment orders were passed without directing production of the relevant books of account and supporting records, though such an opportunity was necessary for an effective examination of the objections. The Assessing Officer was expected to independently apply his mind to the objections and supporting material, and not merely proceed on the basis of the inspection team's proposal. Reliance on the inspection report could at best form the basis for the notice, but the final assessment had to be made on an independent consideration of the dealer's response and documentary evidence.

Conclusion: The impugned assessment orders were set aside and the matters were remanded to the Assessing Officer for fresh consideration after calling for the relevant records and giving the assessee a personal hearing.

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