Assessment orders beyond revision notice scope were set aside for lack of proper notice and application of mind.

Assessment orders based on grounds beyond the scope of the revision notices were held unsustainable because the authority proceeded on additional and different issues without issuing a fresh, clear notice or properly applying its mind to the dealer's explanation. The notices had proposed only specific issues, yet the final assessments departed from that basis, which vitiated the validity of the orders. The assessment orders were set aside, and the authority was directed to issue fresh notices, receive objections, and redo the assessments in accordance with law.

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Issues: Whether the impugned assessment orders were liable to be set aside for travelling beyond the scope of the revision notices and for being passed without proper application of mind.

Analysis: The assessment orders were founded on grounds that were not contained in the revision notices. The notices proposed two specific issues, but the final assessments proceeded on additional and different grounds. The authority also accepted part of the dealer's explanation regarding incorrect adoption of figures, yet continued the assessment on an entirely different basis without issuing a fresh and clear notice. Such deviation from the proposed basis of action affected the validity of the assessment itself.

Conclusion: The impugned assessment orders were unsustainable and were set aside. Fresh notices were directed to be issued, objections were to be received, and the assessments were to be redone in accordance with law.

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