Natural justice in tax assessment requires meaningful disclosure and opportunity before finalising suppression-based additions.

An assessment under section 27 of the Tamil Nadu Value Added Tax Act, 2006 was found vulnerable where the pre-revision notices did not supply the requested return copies, connected records, or break-up details of alleged suppressed purchases, and the order gave no reasons for rejecting those requests. On that factual basis, the Court held that the assessee was denied a fair and effective opportunity and that the principles of natural justice were not satisfied. The assessment order was quashed and the matter was remitted for fresh pre-revision notice and reconsideration after affording sufficient opportunity, including personal hearing.

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Issues: Whether the assessment order passed under section 27 of the Tamil Nadu Value Added Tax Act, 2006 was liable to be quashed for want of adequate opportunity and violation of principles of natural justice.

Analysis: The pre-revision notice disclosed the names of some other end sellers, but the request for return copies and connected records was not considered. The second pre-revision notice also did not furnish break-up details of the alleged suppressed purchases. The impugned assessment order did not record reasons for rejecting the request for relevant particulars. In the circumstances, the petitioner was not afforded a fair and effective opportunity before the assessment was finalised.

Conclusion: The assessment order was quashed and the matter was remitted for fresh pre-revision notice and fresh consideration after giving sufficient opportunity, including personal hearing.

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