Natural justice in reassessment proceedings fails where repeated opportunities were given but not used, and rectification requests lacked supporting documents.

Sufficient notice and repeated opportunities to produce books and supporting documents were given in the re-assessment proceedings, and the matter was even kept in abeyance to enable participation. On that factual basis, a later complaint of breach of natural justice and denial of hearing was not accepted. The rectification applications were also found unsustainable because they were not backed by the required documents, time had been granted to supply them, and the dealer failed to comply within the stipulated period. The third rectification application was treated as non-entertainable in light of the earlier rejections and repeated defaults, and the challenge to the re-assessment and rectification orders was rejected.

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Issues: Whether the re-assessment order and the rejection of the rectification applications were liable to be interfered with on the ground of breach of natural justice and denial of opportunity of hearing.

Analysis: The assessment record showed that notice was issued and served, repeated opportunities were granted to the dealer to produce books and supporting documents, and the proceedings were kept in abeyance to enable participation. The Court held that where sufficient opportunities were provided but not availed, a later challenge alleging denial of hearing cannot succeed. As regards the first and second rectification applications, the Court noted that the applications were unsupported by the necessary documents and that time had been granted to furnish them, but the petitioner failed to do so within the stipulated period. The third rectification application was also not entertainable in view of the earlier rejections and the petitioner's repeated defaults.

Conclusion: The challenge to the re-assessment order and the orders rejecting the rectification applications was rejected; the authorities' actions were upheld.

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