Personal hearing before assessment revision: representation must be reconsidered and decided after hearing.

Where a proposed revision of assessment arose from departmental verification, the dispute at that stage was confined to consideration of the petitioner's detailed representation rather than final adjudication on assessment merits. The HC treated the request for reconsideration as warranting fresh examination and an opportunity of personal hearing before any further order was passed. The respondent was therefore directed to consider the representation dated 08.02.2021 and pass appropriate orders after granting a personal hearing.

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Issues: Whether the respondent should be directed to consider the petitioner's representation and afford a personal hearing before passing further orders.

Analysis: The impugned proceedings arose from a proposed revision of assessment based on departmental verification. The petitioner asserted that the turnover figures had been properly accounted for and sought reconsideration of the matter through a detailed representation. As the dispute at this stage centered on consideration of that representation, and not on adjudication of the assessment merits, the matter warranted a direction for fresh consideration with an opportunity of hearing.

Conclusion: The respondent was directed to consider the petitioner's representation dated 08.02.2021 and pass appropriate orders after granting a personal hearing.

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