Natural justice in reassessment requires mandatory personal hearing before finalising a fresh assessment after remand.

Section 27 of the Tamil Nadu Value Added Tax Act, 2006 requires a reasonable opportunity of hearing, and section 27(4) makes personal hearing mandatory before a fresh assessment is finalised. As no personal hearing was afforded after remand, the revised assessment was found to be in breach of natural justice and could not be sustained. The impugned order was set aside and the matter was remanded for fresh consideration after granting reasonable opportunity, including personal hearing.

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Issues: Whether the revised assessment order was liable to be set aside for violation of natural justice on the ground that the assessee was not granted personal hearing and reasonable opportunity before fresh assessment.

Analysis: Section 27 of the Tamil Nadu Value Added Tax Act, 2006 contemplates reasonable opportunity, and Section 27(4) makes personal hearing mandatory. The record showed that no personal hearing had been afforded before the impugned order was passed after remand. In such circumstances, the assessment could not be sustained and required reconsideration.

Conclusion: The impugned order was set aside and the matter was remanded for fresh consideration after granting reasonable opportunity including personal hearing.

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