Authenticated copies of relied-upon documents must be supplied before tax adjudication when adverse action is based on those materials.

Where show cause notices in a taxation matter rely on specific annexed documents, the department must furnish authenticated copies of those materials before adjudication. Mere inspection is not an adequate substitute unless supplying copies is impracticable or the setting is materially different, such as where the records are voluminous. The operative principle is that a person facing adverse action must receive the material relied upon against him to enable an effective reply. The petitioner was therefore entitled to authenticated copies, and further proceedings could continue only after disclosure.

---

---

Issues: Whether the department was bound to furnish authenticated copies of the documents relied upon in the show cause notices before proceeding with adjudication.

Analysis: The notices specifically relied upon the documents listed in the annexure, so the petitioner was entitled to full disclosure of those materials. The Court distinguished cases where inspection or photocopying was treated as sufficient because the documents were voluminous or the factual setting was materially different. It held that in a taxation matter, where the documents are relied upon to initiate adverse action and there is no showing that supplying copies is impracticable, mere inspection is not an adequate substitute for furnishing authenticated copies. This requirement follows the settled rule that a person must be given the material relied upon against him so that an effective explanation can be filed.

Conclusion: The petitioner was entitled to authenticated copies of the relied upon documents, and the respondents could proceed only after supplying them.

---