Natural justice and personal hearing requirements led to remand after assessment orders ignored objections and relied on inspection findings.

Assessment orders were held unsustainable where the Assessing Officer failed to independently consider the assessee's detailed objections and merely reproduced them without reasoned findings. The Court held that an inspection report and an alleged admission during inspection cannot be treated as conclusive without independent application of mind, particularly when liability is disputed. It also found a breach of natural justice because no personal hearing was granted, despite the circular requiring such opportunity, especially where penalty was proposed. The writ petitions were allowed and the matters were remanded for fresh assessment after considering the objections and granting personal hearing.

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Issues: Whether the assessment orders were vitiated for non-consideration of objections and denial of personal hearing, warranting interference and remand.

Analysis: The assessee filed detailed objections to the notices of proposal, but the assessment orders merely reproduced those objections without recording any reasoned finding as to why they were unacceptable. The assessment was sustained only on the basis of the inspection report and the alleged admission said to have been made during inspection, without independent application of mind by the Assessing Officer. The Court held that a quasi-judicial authority must decide the matter independently and cannot treat an inspection report as conclusive, especially when the assessee disputes liability. The Court also noted that no personal hearing was granted, despite the circular stating that such opportunity is mandatory, particularly where penalty is proposed.

Conclusion: The assessment orders were unsustainable for breach of natural justice and absence of personal hearing, and the writ petitions were allowed with remand for fresh assessment after considering the objections and granting personal hearing.

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