Natural justice in reassessment requires disclosure of mismatch particulars and meaningful hearing before finalising proceedings.

Reassessment and penalty proceedings based on an alleged web-report mismatch were procedurally defective because the dealer was not furnished the mismatch particulars and was not given a meaningful opportunity of hearing. The court noted that the show cause notice and final order lacked concrete details of the alleged Annexure-I and Annexure-II discrepancy, and the assessing authority did not follow the procedure prescribed in the departmental circular requiring disclosure of mismatch particulars and compliance with natural justice. The impugned assessment and consequential revision proceedings were therefore set aside, with directions to reconsider the matter after supplying the mismatch details and affording personal hearing.

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Issues: Whether the impugned reassessment and penalty proceedings based on web report mismatch could be sustained without furnishing the mismatch particulars and granting a meaningful opportunity of hearing in accordance with the departmental circular and principles of natural justice.

Analysis: The assessment was founded on alleged mismatch between Annexure-I and Annexure-II data drawn from the Department website, but no concrete particulars were furnished in the show cause notice or in the impugned order. The record showed that the dealer was not given the details necessary to meet the allegation, and the authority did not follow the procedure indicated in the Commissioner's Circular dated 24.02.2021, which required disclosure of mismatch particulars and observance of natural justice before finalising the assessment. In the absence of such particulars and effective hearing, the assessment was held to be procedurally defective.

Conclusion: The impugned assessment and consequential revision proceedings were set aside, and the matter was directed to be reconsidered after furnishing the mismatch details and affording personal hearing to the dealer.

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