Natural justice breach in reassessment: non-speaking order set aside, matter remitted for fresh consideration and personal hearing.

A reassessment order, computation sheet and demand notice were set aside because the authority passed a non-speaking, unreasoned and laconic order without considering the taxpayer's detailed reply and supporting documents to the show-cause notice. The failure to examine those submissions amounted to lack of application of mind and breach of natural justice. The matter was remitted for fresh consideration in accordance with law, with directions to assess the reply and documents and to grant an opportunity of personal hearing.

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Issues: Whether the reassessment order, computation sheet and demand notice were liable to be set aside for non-consideration of the petitioner's reply and supporting documents, and the matter remitted for fresh consideration after personal hearing.

Analysis: The impugned order was found to be non-speaking, unreasoned and laconic. It was recorded that the petitioner had filed a detailed response along with relevant documents in answer to the show-cause notice, but those submissions were neither considered nor appreciated before passing the order. Such non-consideration of the reply and documents amounted to lack of application of mind and violation of the principles of natural justice.

Conclusion: The impugned orders were set aside and the matter was remitted to the authority for fresh consideration in accordance with law after considering the petitioner's reply and documents and after granting an opportunity of personal hearing.

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