Natural justice breach in assessment proceedings led to setting aside of the order and recovery notice, with remand for fresh hearing.

Assessment notices uploaded only in the portal under the additional notices column, without giving the assessee an effective opportunity to notice them or present its case, amounted to a denial of natural justice. The court treated the absence of a meaningful hearing as a clear procedural violation and interfered with the assessment and recovery actions. The impugned assessment order and consequential recovery notice were set aside, and the matter was remitted for fresh consideration after receipt of the reply and grant of personal hearing.

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Issues: Whether the assessment order and consequential recovery notice were liable to be set aside for breach of natural justice and whether the matter required remand for fresh consideration.

Analysis: The notices and order were uploaded only in the portal under the additional notices column, and the petitioner had no effective opportunity to notice them or place its case before the authority. The demand was also recovered during the pendency of the writ petition. In these circumstances, the denial of an opportunity of hearing was held to be a clear violation of natural justice, warranting interference.

Conclusion: The impugned assessment order and consequential recovery notice were set aside and the matter was remitted to the authority for fresh consideration after receipt of reply and grant of personal hearing.

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