Natural justice in tax notices requires full particulars; a vague show cause notice and assessment order were quashed.

A show cause notice must set out the material particulars of the alleged suppressed sales, incorrect recording, or claims and deductions so the assessee can meet the case effectively; a bald notice that omits such details breaches natural justice, and later disclosure at hearing does not cure that defect. The HC quashed the notice and assessment order, and directed fresh notice and fresh adjudication with reasoned consideration of the assessee's contentions.

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Issues: Whether the assessment order and the accompanying show cause notice were liable to be quashed for want of particulars and denial of an effective opportunity to meet the allegations.

Analysis: The notice did not furnish the details of the alleged suppressed sales, incorrect recording, or incorrect claims and deductions. A bald notice that omits the material particulars necessary to answer the proposed demand does not afford a meaningful opportunity of defence. The subsequent disclosure of details at the personal hearing could not cure the foundational defect in the notice. The Court held that future notices must contain every detail required to enable an effective response and that adjudication orders must record reasons dealing with the assessee's contentions.

Conclusion: The show cause notice and the assessment order were quashed for violation of natural justice, and the matter was sent back for issuance of a fresh detailed notice and fresh adjudication.

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