Natural justice in tax recovery requires effective notice and hearing before coercive action, with interim bank account relief possible.

Where a show cause notice is not effectively served and the affected party cannot file a reply, principles of natural justice require that coercive tax recovery not be sustained without a fresh opportunity of hearing. The authority must permit a reply, reconsider the matter, and pass a reasoned order after hearing the affected party. Pending such reconsideration, operational relief may also be granted by directing de-freezing of the bank account, subject to a minimum balance condition. The ultimate liability and any recovery already made remain for fresh determination by the statutory authority.

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Issues: Whether the assessment and recovery action could be sustained when the show cause notice was not effectively received and no reply or hearing had been afforded, and whether consequential relief from bank account freeze was warranted.

Analysis: The petitioner was unable to demonstrate receipt of the show cause notice through the normal portal and, as a result, could not file any reply before the impugned order and recovery steps were taken. In these circumstances, the proceeding was found to have been carried forward without giving the petitioner a fair opportunity to answer the allegations. Since the bank account had already been frozen in connection with the recovery action, continuation of the freeze would impede business operations pending reconsideration of the matter.

Conclusion: The petitioner was entitled to file a reply within the time granted, the authority was required to reconsider the matter after affording an opportunity of hearing and passing a reasoned order, and the bank account was directed to be de-frozen with the stipulated minimum balance condition.

Final Conclusion: The writ petition succeeded only to the extent of securing a fresh opportunity before the authority and interim operational relief regarding the bank account, while the recovery already made and the ultimate liability were left to the statutory authority to determine afresh.

Ratio Decidendi: Where a show cause notice is not effectively served and the affected party is unable to respond, principles of natural justice require a fresh opportunity of hearing before coercive tax recovery is finally sustained.

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