Natural justice in valuation disputes requires notice of the ground relied on before any adverse determination.

A tribunal should not decide a valuation dispute on a ground not set out in the show-cause notice or otherwise put to the parties for response. Where the record shows that the appellants had no opportunity to meet the basis ultimately adopted, and additional documents also require consideration, the proper course is fresh disposal. The matter was therefore remanded to the Tribunal for reconsideration in accordance with law after due notice and opportunity.

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Issues: Whether the Tribunal's decision required to be set aside and the matter remanded for fresh disposal because it proceeded on a ground not put in the show-cause notice and because the appellants were not afforded an opportunity on that basis.

Analysis: The Tribunal had decided the valuation dispute on a different basis from the one adopted in the show-cause notice and the earlier authorities. The record indicated that the appellants had not been put on notice of the ground ultimately relied upon, and the matter also involved additional documents that had not been considered below. In these circumstances, fresh consideration by the Tribunal was necessary.

Conclusion: The matter was required to be remanded to the Tribunal for fresh disposal in accordance with law.

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