Natural justice in CENVAT disputes fails when relied upon documents were substantially supplied and invoices were identifiable.

Where the material relied upon by the authority had substantially been furnished and the disputed invoices were identifiable from the annexure with invoice and supplier particulars, no breach of natural justice was established on the ground of non-supply of relied upon documents. The petitioner was therefore not prevented from verifying the transactions with suppliers, and the challenge to the demand for ineligible CENVAT credit could not be sustained in writ jurisdiction under Article 226. The court found the grievance of non-supply unfounded and dismissed the writ petition.

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Issues: Whether the impugned order was vitiated for violation of principles of natural justice on the ground that copies of relied upon documents were not supplied, and whether the petitioner was entitled to invoke writ jurisdiction to challenge the demand of ineligible CENVAT credit.

Analysis: The only substantial grievance was non-supply of documents. The record showed that most of the required documents had already been handed over with acknowledgment, and the disputed invoices were identified in the annexure with invoice numbers and supplier details. The petitioner was therefore not prevented from verifying the transactions from its suppliers. In these circumstances, the grievance of non-supply was held to be unfounded and no breach of natural justice was established. As the challenge rested solely on that ground, the petitioner was not entitled to invoke Article 226 of the Constitution of India to assail the order.

Conclusion: The challenge based on alleged non-supply of relied upon documents failed, and the writ petition was dismissed.

Ratio Decidendi: Where the material relied upon by the authority has substantially been furnished, and the disputed documents can be identified and verified from the particulars supplied, a plea of violation of natural justice for non-supply of documents is not established so as to warrant interference in writ jurisdiction.

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