Natural justice in tax assessment requires supply of relied-upon documents and fair consideration of the assessee's reply.

An assessment order cannot be sustained where the assessee specifically disputes the alleged purchase transaction, seeks copies of the documents relied on in the pre-revision proceedings, and the assessing authority proceeds without furnishing that material or meaningfully dealing with the reply. The Madras HC noted that tax assessment proceedings require a fair opportunity to meet the case against the assessee, and failure to supply relied-upon documents and objectively consider the objections amounts to breach of natural justice. On that basis, the assessment order was quashed and the matter remanded for fresh consideration after affording sufficient opportunity.

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Issues: Whether the assessment order was liable to be quashed for violation of principles of natural justice due to non-furnishing of requested documents and non-consideration of the assessee's reply.

Analysis: The assessee had specifically denied the alleged inter-State purchase and sought copies of the documents relied upon in the pre-revision proceedings. The assessing authority proceeded to pass the assessment order without supplying the requested material or effectively dealing with the objection. In tax assessment proceedings, a fair opportunity to meet the case against the assessee is mandatory, and an order passed without such opportunity and without objective consideration of the reply suffers from breach of natural justice.

Conclusion: The assessment order was rightly quashed for violation of natural justice, and the matter was remanded for fresh consideration after affording sufficient opportunity.

Ratio Decidendi: An assessment order passed without furnishing relied-upon documents sought by the assessee and without proper consideration of the reply violates the principles of natural justice and cannot be sustained.

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