Show cause notice bias invalidates pre-judged tax notices and violates natural justice, justifying writ interference.

Show cause notices under the Tamil Nadu General Sales Tax Act were invalid where their language showed the authority had already concluded that suppression and evasion were proved beyond doubt. A notice must preserve an open mind and give a genuine opportunity to respond; a pre-judged notice defeats that purpose and violates natural justice. The defect is inherent in the issuance of the notice itself and is not cured by any later direction to consider objections impartially. Writ interference was justified, and the notices were set aside for bias and closed-mindedness.

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Issues: Whether the show cause notices issued under Section 16 of the Tamil Nadu General Sales Tax Act, 1959 were vitiated for revealing a foreclosed or prejudged mind and were therefore liable to be quashed.

Analysis: A show cause notice must reflect an open mind and serve as a real opportunity to explain the proposed action. Where the notice itself states, in categorical terms, that the alleged suppression and evasion are already "proved beyond any shadow of doubt," it demonstrates that the authority has pre-judged the matter. Such a notice is not cured by a subsequent direction to consider objections impartially, because the foundational vice lies in the issuance of the notice itself. The defect amounts to violation of the principles of natural justice and attracts writ interference notwithstanding the availability of further remedies.

Conclusion: The show cause notices were held to be vitiated by bias and a closed mind and were liable to be set aside.

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