Natural justice requirements vitiated the assessments, leading to remand for fresh hearing and a reasoned order.

Failure to comply with earlier writ directions requiring consideration of objections and an opportunity of hearing vitiated the assessment orders. The authority had proceeded without first passing the contemplated speaking order on the petitioner's representation, so the assessments were set aside. The matter was remitted for fresh consideration by the enforcement authority, with directions to hear the petitioner and pass a reasoned order before issuing any fresh notice under the notice provision. The time spent in the writ proceedings was directed to be excluded for limitation purposes.

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Issues: Whether the assessment orders were liable to be quashed for non-compliance with the earlier direction to consider the petitioner's objections and grant an opportunity of hearing, and whether the matter required remand with exclusion of time for limitation purposes under the notice provisions.

Analysis: The impugned assessments were founded on notices already covered by the earlier writ directions, yet the record showed that the authority proceeded without first passing the contemplated speaking order on the petitioner's representation. The failure to comply with the earlier judicial direction and to consider the objections after hearing the petitioner vitiated the assessments. Since the matter had not been properly processed at the stage directed earlier, the appropriate course was to set aside the assessments and remit the matter to the enforcement authority to pass a reasoned order, after hearing the petitioner, before any fresh notice under the notice provision could be issued. The time spent in these proceedings was directed to be excluded for limitation purposes.

Conclusion: The assessment orders were quashed and the matter was remitted for fresh consideration after hearing the petitioner, with the period spent in these writ proceedings excluded for limitation under the notice provision.

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