Natural justice requires that, where a proposed demand under tax...

Natural justice requires that, where a proposed demand under tax adjudication rests on relied-upon documents, those documents must be supplied before the noticee is expected to reply. The Court treated the absence of satisfactory material showing prior supply, coupled with the contrary plea, as sufficient to proceed on the basis that the noticee had not received the documents before confirmation of demand. That procedural defect vitiated the adjudication, and the matter was remitted for fresh supply of the show cause notice, relied-upon documents and list of non-relied-upon documents, consideration of any further document request, and continuation only after due opportunity.

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