Natural justice in revisional proceedings requires a fair hearing before adverse orders, or the order may be set aside.

A quasi-judicial revisional authority must afford the affected party a fair and meaningful opportunity of hearing before passing an adverse order. Where the record does not satisfactorily show compliance with audi alteram partem, especially when the order carries serious civil consequences, the revisional order is unsustainable and liable to be set aside. The matter is then restored for fresh decision by the competent authority after hearing the party and considering all pleas in accordance with law, while other jurisdictional objections may be raised on remand.

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Issues: Whether the revisional order was liable to be set aside for breach of natural justice inasmuch as the affected party was not afforded a fair personal hearing before the adverse order was passed.

Analysis: The revisional authority was exercising quasi-judicial jurisdiction and was therefore required to comply with the rule of audi alteram partem. Although a reply to the notice had been filed, the record did not satisfactorily show that the party was given a fair and meaningful opportunity to place its version before the authority. Since the impugned order had serious civil consequences, adherence to the principles of natural justice was mandatory. The other grounds concerning the competency and timing of invocation of revisional power under the tax regime were left to be urged before the authority on remand.

Conclusion: The impugned revisional order was unsustainable for violation of natural justice and was set aside.

Final Conclusion: The matter was restored for a fresh decision by the competent authority after hearing the party and considering all pleas in accordance with law.

Ratio Decidendi: A quasi-judicial revisional authority cannot pass an adverse order without affording the affected party a fair opportunity of hearing, and an order passed in breach of audi alteram partem is liable to be set aside.

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