Natural justice and alternate remedy in reassessment: non-supply of report did not invalidate proceedings, writ not entertained.

A reassessment challenge raised two issues: whether non-supply of the special investigation report vitiated the proceedings for breach of natural justice, and whether writ jurisdiction should be exercised despite an available statutory appeal. The Court stated that the petitioners themselves had to establish the genuineness of the disputed C-forms, and the mere source of suspicion or non-supply of the report did not, by itself, amount to denial of a fair hearing. It also declined to examine the merits because an efficacious alternative appellate remedy was available against the reassessment order.

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Issues: Whether the reassessment order was vitiated by breach of natural justice for supply of the special investigation report, and whether the writ petitions should be entertained despite the availability of an efficacious statutory appeal.

Analysis: The reassessment arose after the assessing authority proceeded on the genuineness of disputed C-forms and the petitioners sought the special investigation report. The Court held that the petitioners alone could establish the genuineness of the C-forms, and the source of suspicion or non-supply of the report did not, by itself, show denial of a fair hearing. Since the petitioners had the statutory remedy of appeal against the reassessment, the Court declined to enter the merits.

Conclusion: There was no violation of natural justice, and the writ petitions were not entertained in view of the efficacious alternative statutory remedy.

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