Natural justice in appellate proceedings requires a proper hearing before dismissal; matter remanded for fresh merits consideration.

An appellate order dismissing an assessee's appeal without deciding the dispute on merits was held unsuitable for final disposal where the record did not show how or when notices were served. The matter was remanded for fresh adjudication because substantial justice required a reasonable opportunity for the assessee to present submissions and supporting documents before the appellate authority. The appellate authority was directed to reconsider the matter on merits after granting such opportunity.

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Issues: Whether the appellate order dismissing the assessee's appeal without adjudication on merits required interference and remand for fresh consideration.

Analysis: The appellate order did not disclose the mode or dates of service of notices and did not decide the dispute on merits. In the interest of substantial justice, the matter required reconsideration after affording the assessee a reasonable opportunity to place its submissions and supporting documents before the appellate authority.

Conclusion: The matter was remanded to the appellate authority for fresh on merits after granting reasonable opportunity to the assessee.

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