Natural justice in tax assessment requires a meaningful hearing where notice was not effectively received and documents remain to be produced.

An assessment made during the Covid-19 lockdown was set aside where the dealer credibly claimed non-receipt of the notice and sought an opportunity to produce the required declaration forms. The Court accepted that exceptional circumstances and the closure of the Guntur office could have prevented effective receipt and response, and held that the authority should have granted a meaningful hearing before finalising the tax liability. The matter was remitted for reconsideration after allowing the dealer to submit the relevant documents and be heard, applying the principles of natural justice.

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Issues: Whether the assessment order could be sustained when the dealer claimed non-receipt of the notice and sought an opportunity to produce 'H' and 'F' declaration forms after the assessment.

Analysis: The assessment was made during the Covid-19 lockdown period, and the petitioner asserted that the office at Guntur had been closed and business operations were being carried on from Chennai. The Court found substance in the plea that the order had not been effectively received in those circumstances. Since the petitioner expressed readiness to produce the relevant declaration forms, the Court held that the matter should be considered after granting an opportunity consistent with the principles of natural justice.

Conclusion: The assessment order was set aside and the petitioner was to be afforded an opportunity to submit the relevant documents and be heard before a fresh decision was taken.

Final Conclusion: The petitioner succeeded on the ground of denial of a fair opportunity, and the assessment was remitted for reconsideration in accordance with law.

Ratio Decidendi: Where an assessee shows a credible inability to receive or respond to the assessment proceedings due to exceptional circumstances and seeks to place material evidence on record, the authority should grant a meaningful opportunity before finalising the tax liability.

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