Natural justice breach in tax assessment led to remand for fresh adjudication without deciding input tax credit merits.

Long unexplained gaps, failure to consider the earlier notice and reply, and issuance of later assessment notices without carrying the matter to its logical end were treated as procedural defects breaching natural justice. The HC therefore directed that the impugned proceedings be treated as show cause notices and sent back for fresh objections, hearing, and reassessment by the authority. It declined to decide the nature of the transaction or the petitioner's entitlement to input tax credit under Section 4(2) of the Tamil Nadu Value Added Tax Act, 2006, holding that those issues must be examined on the records before the assessing authority.

---

---

Issues: Whether the impugned assessment proceedings and orders required interference for want of fair consideration and whether the matter should be remitted for fresh adjudication.

Analysis: The proceedings were marked by long unexplained gaps, non-reference to the earlier notice and reply exchanged between the parties, and failure to carry the matter to its logical end before issuing the later impugned notice and orders. The Court found that these procedural lapses rendered the process flawed and amounted to a breach of natural justice. At the same time, the Court declined to record any factual finding on the nature of the transaction or on the petitioner's entitlement to input tax credit under Section 4(2) of the Tamil Nadu Value Added Tax Act, 2006, holding that those questions had to be examined on the records and documents before the assessing authority.

Conclusion: The impugned proceedings were not finally adjudicated on merits and were directed to be treated as show cause notices for fresh objections, hearing, and reassessment by the authority.

Ratio Decidendi: Where the assessment process is procedurally defective and relevant earlier proceedings are ignored, the matter may be remitted for fresh consideration without deciding the underlying taxability issue on merits.

---