Proper service of reassessment notice is essential; notice sent to an outdated address violated natural justice and invalidated the assessments.

Reassessment notice must be served at the taxpayer's correct correspondence address where the department's records have been updated, and service at an old address does not satisfy the statutory requirement. Here, the taxpayer had informed the authorities of the change of address, yet the notice was sent to the earlier address reflected no longer in use. The Court treated this as ineffective service of the pre-reassessment notice and a denial of a fair opportunity to respond, and the assessment orders were set aside for breach of natural justice.

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Issues: Whether the assessment orders were liable to be set aside for want of proper service of notice and denial of a fair opportunity before reassessment.

Analysis: The petitioner had intimated the tax authorities of a change in correspondence address, and the corrected address was reflected in the registration records. The reassessment notice was nevertheless dispatched to the earlier address. In these circumstances, the Court found that the notice was not served on the correct address maintained by the department. Since the statutory notice preceding reassessment was not effectively served, the petitioner was denied a fair opportunity to respond before the assessment orders were passed.

Conclusion: The assessment orders were held vitiated for violation of natural justice and were set aside.

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