Natural justice in reassessment demands personal hearing and reasoned consideration of objections before revision is sustained.

A reassessment under Section 27 of the Tamil Nadu VAT Act was found unsustainable because the assessee's objections to the pre-revision notice were not considered by a reasoned order and no personal hearing was granted. The Court treated personal hearing in assessment revision proceedings as mandatory, and held that denial of that opportunity violated natural justice. The reassessment order was therefore set aside and the matter remanded for fresh consideration after giving the assessee an opportunity of hearing.

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Issues: Whether the revision of assessment under Section 27 of the Tamil Nadu Value Added Tax Act, 2006 could be sustained when the assessee was not afforded personal hearing and the objections to the pre-revision notice were not considered by a reasoned order.

Analysis: The assessee had filed a detailed reply to the pre-revision notice and specifically sought personal hearing. The impugned order acknowledged receipt of the objections, but it rejected them in a brief manner without addressing the objections on merits. The Court noted that a personal hearing is mandatory in assessment revision proceedings and that denial of such opportunity vitiates the order as it offends natural justice.

Conclusion: The reassessment order was held to be unsustainable for want of personal hearing and proper consideration of objections, and the matter was remanded for fresh decision after giving the assessee an opportunity of hearing.

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