Natural justice requires personal hearing before assessment; lack of opportunity to produce documents led to remand for reconsideration.

An assessment completed without granting the dealer a meaningful personal hearing or an opportunity to produce supporting material was held procedurally unfair and unsustainable. The record indicated that the dealer had sought time to place documents relating to C-forms, export sales and the nature of job work, but the orders were passed without considering that request. The assessment orders were therefore set aside and the matters remanded for fresh consideration, with directions to verify the relevant C-forms and export documents and to proceed under the Tamil Nadu Value Added Tax Act if any reversal of input tax credit was warranted.

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Issues: Whether the impugned assessment orders were liable to be set aside for want of personal hearing and violation of principles of natural justice, and the matters remanded for fresh consideration.

Analysis: The assessment was completed without affording the dealer an opportunity of personal hearing. The record showed that the petitioner had sought time to produce supporting material on C-forms, export sales, and the nature of job work, but the order was passed without considering such opportunity. In these circumstances, the assessment was found to be procedurally unfair and unsustainable. The court also directed that, on remand, the assessing authority should verify the relevant C-forms and export documents and, if any reversal of input tax credit was required, proceed under the Tamil Nadu Value Added Tax Act.

Conclusion: The assessment orders were set aside and the matters were remanded for fresh consideration after affording personal hearing.

Ratio Decidendi: An assessment completed without giving the assessee a meaningful opportunity of personal hearing and to produce supporting documents is vitiated by breach of natural justice and must be remitted for reconsideration.

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