Effective personal hearing is mandatory before reassessment where objections raise complex issues and natural justice is at stake.

Assessment orders under the Kerala Value Added Tax Act were found to be vulnerable where the assessee had filed further objections but was not granted a clear and effective personal hearing before finalisation. The record showed notices, replies and adjournments, yet no meaningful hearing after the later objections, and the authority could not assume that hearing would be an empty formality. Because the reassessment involved complex issues and substantial financial consequences, a fresh hearing date was required. The orders were set aside for breach of natural justice and remitted for reconsideration after hearing the assessee.

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Issues: Whether the assessment orders passed under Section 25(1) of the Kerala Value Added Tax Act, 2003 were liable to be set aside for denial of effective opportunity of personal hearing and breach of natural justice.

Analysis: The record showed notice, replies, and adjournments, but no clear and effective personal hearing after the assessee filed further objections on 01.03.2019. In the circumstances, the authority could not treat a hearing on the objections as unnecessary on the assumption that it would be an empty formality. Where the reassessment involved complex issues and substantial financial consequences, a clear hearing date after receipt of objections was required before finalising the assessment.

Conclusion: The assessment orders were vitiated for want of effective opportunity of hearing and were set aside, with the matters remitted to the assessing authority for fresh disposal after hearing the petitioner.

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