Violation of principles of natural justice found ineffective reply; petitioner granted liberty to pursue statutory remedy by timely filing appeal.

Alleged violation of principles of natural justice was examined and the respondent's rejection of the petitioner's reply was upheld on the basis that the reply was neither proper nor effective, and the petitioner had been afforded adequate opportunities but failed to avail personal hearing and file an effective response; consequence: the impugned assessment orders require no interference. The petitioner was directed to pursue the available statutory remedy and was granted liberty to file a timely appeal against the impugned assessment orders, and the petition was dismissed.

---

---

Issues: Whether the impugned assessment orders dated 29.09.2025 require interference on the ground of violation of principles of natural justice and inadequate consideration of the petitioner’s reply, and whether the petitioner should be granted liberty to file an appeal against the assessment orders.

Analysis: The Court examined the procedural history showing issuance of show cause notices and filing of replies by the petitioner, followed by multiple notices affording opportunities for personal hearing. The Court found that the petitioner failed to appear despite repeated opportunities and that the replies filed were not proper or effective. The Court noted that where an assessee has not availed the afforded opportunities and the reply is insufficient, the principles of natural justice are not infringed. The Court also considered the availability of alternative remedy before the Appellate Authority, which possesses the power to adjudicate afresh and afford hearing, and observed that time remains available for filing an appeal.

Conclusion: The impugned assessment orders do not warrant interference and the petitions are dismissed; however, the petitioner is granted liberty to file an appeal before the Appellate Authority within two weeks, who shall consider the appeal on merits and in accordance with law by providing sufficient opportunity to the petitioner.

Ratio Decidendi: Where an assessee, after filing replies, fails to avail repeated opportunities of personal hearing and the replies are found insufficient, a court will not interfere with the assessment order and the appropriate remedy is to seek adjudication before the Appellate Authority which must be allowed to consider the matter on merits.

---