Natural justice in assessment proceedings requires a meaningful chance to object and be heard before adverse tax orders are confirmed.

An assessment order passed without a meaningful opportunity to file objections or obtain a personal hearing was held to violate natural justice. The Telangana HC noted that the Covid-19 lockdown and the petitioner's inability to access documents or consult counsel made effective response to the show-cause notice difficult, yet the order was still issued. The order was therefore set aside and remitted to the assessing authority for fresh consideration after granting an opportunity to object and be heard. The merits of the tax liability, including limitation, were left open on remand.

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Issues: Whether the assessment order was vitiated for violation of principles of natural justice and required to be set aside and remitted for fresh consideration.

Analysis: The assessment was made during the Covid-19 lockdown period, when the petitioner's consultant was unavailable and access to documents needed to meet the show-cause notice was difficult. The petitioner had sought time and a personal hearing, but the order was passed without affording that opportunity. In these circumstances, the denial of an effective opportunity to file objections and present supporting material amounted to a breach of natural justice.

Conclusion: The assessment order was rightly set aside and the matter was remitted to the assessing authority for fresh consideration after granting opportunity of objections and personal hearing.

Final Conclusion: The petitioner obtained relief against the impugned assessment, while the merits of the tax liability, including limitation, were left open for adjudication by the assessing authority on remand.

Ratio Decidendi: An assessment order passed without a meaningful opportunity to file objections and be heard, particularly where the assessee is disabled by exceptional circumstances from effectively responding to the show-cause notice, is liable to be set aside and remitted for de novo consideration.

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