Natural justice in assessment proceedings requires personal hearing and fair opportunity before finalisation; impugned order was quashed and remanded.

Denial of personal hearing and inadequate opportunity to file objections before finalisation of the assessment violated the principles of natural justice. The Madras High Court, following its earlier view on similar facts, held that an assessment cannot be sustained where the assessee was not given a reasonable chance to place objections on merits. The impugned assessment order was quashed and the matter was remanded for fresh consideration, with directions to grant personal hearing and permit all objections available in law.

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Issues: Whether the impugned assessment order was liable to be quashed for denial of personal hearing and inadequate opportunity before the assessment was finalised.

Analysis: The assessment was challenged on the ground that no personal hearing was afforded and that the assessee was not given a fair opportunity to place objections on merits. The Court followed the earlier order of the same Court on similar facts, where denial of hearing was held to amount to violation of the principles of natural justice. Since the dispute arose in the context of the pending challenge to the amendment and the assessee had not been given reasonable opportunity before the impugned order was passed, the assessment could not be sustained.

Conclusion: The impugned assessment order was quashed and the matter was remanded to the authority for fresh consideration after granting reasonable opportunity of personal hearing and permitting all objections available in law.

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