Natural justice in tax assessment requires consideration of objections and a personal hearing before adverse orders are passed.

The assessment order was vitiated for breach of natural justice because the assessee's reply and the customer's clarification that the purchase turnover had been wrongly linked to a closed concern were not considered. The Court held that the requirement of reasonable opportunity under Sections 22 and 27 of the Tamil Nadu Value Added Tax Act, 2006 includes a right to personal hearing before an adverse order is passed. As no such hearing was granted and the objections were left unaddressed, the assessment order was quashed and the matter remanded for fresh assessment after giving adequate opportunity, including personal hearing.

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Issues: Whether the assessment order was liable to be quashed for violation of natural justice in view of non-consideration of the reply and denial of personal hearing.

Analysis: The reply filed by the assessee, along with the customer's clarification that the purchase turnover had been mistakenly linked to a closed concern instead of the actual selling concern, was not considered in the assessment order. The statutory requirement of reasonable opportunity under Sections 22 and 27 of the Tamil Nadu Value Added Tax Act, 2006 was held to include a right of personal hearing, particularly before passing an adverse order. Since no such opportunity was afforded and the objections were not dealt with, the order was vitiated by breach of natural justice.

Conclusion: The assessment order was quashed and the matter was remanded for fresh assessment after granting adequate opportunity, including personal hearing, to the assessee.

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