SLP dismissed; revised tax assessments quashed for violating natural justice, factual findings under Article 136 left undisturbed

SC dismissed the revenue's SLP, thereby affirming the HC's common order quashing the revised assessment orders passed against the dealer. The HC had held that the non-furnishing of the D3 report and related records, which formed the basis of the revised assessments, constituted a violation of principles of natural justice, particularly audi alteram partem, as the dealer was denied an effective opportunity to contest the material relied upon. SC found no error or perversity warranting interference under Article 136 and declined to reappreciate the factual findings of procedural unfairness. The HC's directions regarding the assessments thus stood confirmed.

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The Supreme Court dealt with Special Leave Petitions challenging a common order of the High Court. The Court first addressed limitation and held that the "delay [is] condoned," thereby allowing the petitions to be considered on merits despite being filed late. After hearing the petitioner's counsel and examining the record, the Court expressly stated it was "not inclined to interfere with the common impugned order passed by the High Court." Consequently, the Special Leave Petitions were dismissed, leaving the High Court's decision undisturbed. The Court further directed that all "pending applications, if any, also stand disposed of," thereby conclusively terminating all related interlocutory proceedings.

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