Court quashes assessment orders, directs compliance with legal requirements, grants fair opportunity for objections. Emphasizes expeditious process.

The court quashed the assessment orders and recovery notices, directing the respondent to reinitiate the process adhering to legal requirements and granting the petitioner a fair opportunity to present objections. The court emphasized expeditious completion of the revised assessment process. The writ petitions were allowed, and no costs were imposed, leading to the closure of the connected miscellaneous petitions and resolution of the legal dispute.

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Issues:
Challenging impugned assessment orders for multiple assessment years.

Analysis:
The petitioner, engaged in textile and garment trading, faced inspection leading to assessment orders for various years. The petitioner raised objections to the assessment, citing incorrect quantification and procedural irregularities. The petitioner argued that inspection and investigation were flawed, leading to unjust demands. The respondent issued notices and conducted personal hearings, but the petitioner's objections were dismissed without proper consideration. The respondent's actions were deemed unfair and in violation of natural justice principles.

The petitioner sought relief based on legal provisions and circulars, highlighting past court decisions supporting their stance. The respondent, however, contended that the notices and assessments were valid, emphasizing the burden of proof on the dealers to show tax compliance. The respondent defended the assessment process as per the law, including issuing proper notices and conducting personal hearings before passing orders.

Upon review, the court found discrepancies in the assessment process, noting failures to follow prescribed procedures and principles of natural justice. The court quashed the assessment orders and recovery notices, directing the respondent to reinitiate the process adhering to legal requirements and granting the petitioner a fair opportunity to present objections. The court emphasized expeditious completion of the revised assessment process.

In conclusion, the writ petitions were allowed, and no costs were imposed. The connected miscellaneous petitions were closed, signaling the resolution of the legal dispute.

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