Reasoned tax assessment is mandatory: premature revision and unexplained stock-difference computation breach natural justice requirements.

Under the Tamil Nadu Value Added Tax Act, revision proceedings based on an enforcement-wing inspection must await the date on which the return is deemed assessed where they are not best-judgment assessments. A revision notice issued earlier is premature and unsustainable. An assessment must also address material objections to the method used for computing stock difference and provide reasons for rejecting them. Cryptic rejection of objections, without explaining the formula-based computation, denies the assessee knowledge of the grounds for rejection and breaches principles of natural justice. The assessment requires fresh consideration with credit for amounts already paid.

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Issues: (i) Whether a revision notice and assessment based on an enforcement-wing inspection could be initiated before the date on which the return was deemed assessed; (ii) Whether the assessment order was sustainable despite failing to give reasons for rejecting objections concerning the method used to determine stock difference.

Issue (i): Whether a revision notice and assessment based on an enforcement-wing inspection could be initiated before the date on which the return was deemed assessed.

Analysis: The proceeding was initiated through a revision notice based on an inspection report, with penalty also proposed. It was not a best judgment assessment under Section 22(4) of the Tamil Nadu Value Added Tax Act, 2006. The assessing authority was required to await the deemed-assessment date before initiating such revision.

Conclusion: The revision notice issued before the deemed-assessment date was premature and unsustainable in law, in favour of the assessee.

Issue (ii): Whether the assessment order was sustainable despite failing to give reasons for rejecting objections concerning the method used to determine stock difference.

Analysis: The objections specifically challenged the formula-based computation of stock difference and relied on authorities questioning that method. The order neither addressed those objections nor justified the adopted method, and rejected the objections through cryptic observations. The assessee was thereby denied knowledge of the grounds on which its claim was rejected, offending principles of natural justice.

Conclusion: The non-speaking assessment order was unsustainable for violation of principles of natural justice, in favour of the assessee.

Final Conclusion: The impugned assessment could not stand; the assessing authority must undertake fresh consideration while giving credit for the amount already paid.

Ratio Decidendi: An assessment that rejects material objections without addressing the challenge to the adopted method or supplying reasons is invalid for breach of principles of natural justice.

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