Natural justice in valuation disputes requires a fair hearing before assessing job-work goods and deciding assessable value.

An assessment of goods processed on a job-work basis was set aside because the valuation controversy raised before the Tribunal had not been properly addressed and the assessee had been denied an effective opportunity to present its case on the components forming the assessable value. The Supreme Court held that the authorities below failed to consider this issue and that fresh consideration was required after hearing the assessee. The assessment order and appellate affirmation were therefore set aside, and the matter was remitted to the assessing authority to allow objections and reconsider valuation afresh.

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Issues: Whether the assessment order on the valuation of goods processed on job work basis, as affirmed in appeal, was liable to be set aside and remitted for fresh consideration in the absence of an opportunity to place the assessee's case.

Analysis: The order proceeded without considering the valuation controversy that had arisen in the Tribunal and without giving the assessee an opportunity to present its case on the components to be included in assessable value. The Court found that the authorities below had not addressed this aspect and that the assessee had been denied a proper opportunity of hearing.

Conclusion: The assessment order and the appellate affirmation were set aside and the matter was remitted to the assessing authority for fresh consideration after permitting the assessee to file objections.

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