Natural justice in customs valuation requires disclosure of comparable import records needed to answer the show cause notice fairly

In quasi-judicial customs adjudication, natural justice requires disclosure of materials relied upon by the authority when those records are relevant to the proposed liability or duty burden. Comparable import valuation and assessment details already in the authority's possession, including particulars of identical goods from the same supplier, should be furnished where they may support objections to the show cause notice or a plea of discriminatory treatment. Withholding such information would deny a fair opportunity to respond. The authority was required to provide the requested records and particulars so the affected party could rely on them in the adjudication.

---

---

Issues: Whether the customs authority was bound to furnish the records and valuation details of comparable imports relied upon by other importers so that the petitioner could effectively file objections in the adjudication proceedings.

Analysis: In quasi-judicial proceedings that may fasten civil liability or tax/duty burden, the principles of natural justice require disclosure of the materials relied upon against the affected person. Where the requested particulars are already available with the authority and are relevant to the adjudication, withholding them would impede a fair opportunity to answer the show cause notice. The information sought here related to valuation and assessment of identical goods imported from the same supplier and could support the petitioner's objections, including a plea of discriminatory treatment. The Court held that there was no legal impediment to furnishing such materials and that fairness and reasonableness required disclosure.

Conclusion: The respondent was required to furnish the requested records and particulars, and the petitioner was entitled to rely upon them before the adjudicating authority.

Ratio Decidendi: In quasi-judicial customs adjudication, materials relied upon by the authority and relevant comparable records in its possession must be disclosed to the affected party to satisfy natural justice and fairness.

---