Mandatory personal hearing and full mismatch disclosure are required before revised assessment; omission vitiates the order.

A revised assessment was held unsustainable where the pre-revision notice omitted invoice-wise mismatch particulars required by Circular No. 10 of 2015, preventing an effective response. The absence of disclosed particulars, together with the failure to afford personal hearing before passing the revised assessment, violated the mandatory requirement of hearing. The fact that no objections were filed to the notice did not justify denial of personal hearing. The assessment was set aside and the matter remitted for fresh consideration after proper notice, disclosure of particulars, and personal hearing.

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Issues: Whether the revised assessment order was vitiated for want of disclosure of mismatch particulars in the pre-revision notice and for denial of an opportunity of personal hearing.

Analysis: The pre-revision notice was issued without enclosing the invoice-wise mismatch particulars required under Circular No. 10 of 2015 dated 01.04.2015, leaving the assessee unable to effectively respond. The order also did not show that a personal hearing was afforded before passing the revised assessment. The requirement of hearing is mandatory even if objections are not filed to the notice, and failure to submit objections does not justify denial of personal hearing.

Conclusion: The revised assessment order was unsustainable and was set aside, with the matter remitted for fresh consideration after issuing a proper notice, furnishing the relevant particulars, and granting personal hearing.

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