Natural justice requires detailed notice before revisional disallowance of exemption in sales tax assessment.

A revisional assessment disallowing exemption on interstate purchase of building materials was held unsustainable where the proposal notice did not disclose the material particulars and grounds later relied on in the final order. The exemption under Section 3B(2)(b) of the Tamil Nadu General Sales Tax Act had been accepted in the original assessment, but the revisional reasons were introduced only in the assessment order, depriving the assessee of an effective opportunity to meet the case against it. The merits of the exemption claim were not finally examined; the matter was remitted for fresh consideration after a detailed notice.

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Issues: Whether the revisional assessment disallowing exemption on interstate purchase of building materials could be sustained when the notice of proposal did not disclose the material particulars and grounds later relied upon in the assessment order.

Analysis: The exemption claimed under Section 3B(2)(b) of the Tamil Nadu General Sales Tax Act, 1959 had been accepted in the original assessment. The notice proposing revision did not contain the factual basis or material particulars necessary to meet the proposed disallowance. The reasons ultimately used in the revisional order were introduced for the first time in the final order and were not part of the notice, depriving the assessee of an effective opportunity to answer the case against it. The merits of the exemption claim were not examined finally because the interference was made on the ground of procedural unfairness.

Conclusion: The revisional order could not be sustained for want of proper notice and compliance with natural justice, and the matter was remitted for fresh consideration after issuing a detailed notice.

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