Year-wise assessment of alleged suppression required; conditional remand granted to balance procedural fairness and revenue protection.

Alleged suppression across multiple years could not be fastened to a single assessment year without proper year-wise consideration, and the revised return filed before inspection could not be disregarded for the relevant period. At the same time, the petitioner's lack of candour in disclosing actual sales justified protecting the revenue's interest. The court therefore granted only conditional further opportunity: the petitioner was allowed to file objections before the Assessing Officer after complying with a payment condition, and the assessment was left open for fresh consideration in accordance with law.

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Issues: Whether the assessment for assessment year 2015-16 could validly proceed on the basis of alleged suppression spanning multiple years and whether the petitioner was entitled to further opportunity before the Assessing Officer.

Analysis: The revised return filed prior to the inspection could not be ignored for the relevant period, while the returns for November and December 2015 were hit by the statutory embargo under the relevant provisions. The impugned order suffered from an error in clubbing alleged purchase suppression from 2010-11 to 2015-16 and bringing it to tax in a single assessment year. At the same time, the petitioner had not been candid in disclosing actual sales, and the revenue's interest required protection. The proper course was to grant one further opportunity, subject to payment of a portion of the disputed tax, and then permit the petitioner to place objections before the Assessing Officer.

Conclusion: The assessment was interfered with only to the extent of granting conditional further opportunity and directing a fresh assessment after hearing, if the petitioner complied with the payment condition.

Final Conclusion: The writ petition was disposed of with conditional relief, leaving the assessment open to be reconsidered in accordance with law upon compliance.

Ratio Decidendi: An assessment cannot validly fasten liability for a single assessment year by clubbing alleged suppression across multiple years without proper year-wise consideration, and conditional remand may be ordered to balance procedural fairness with revenue protection.

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