3.The then Assessing Officer had issued two notices dated 18.10.2013 and 23.10.2013, alleging that the petitioner has effected purchases of goods from the Registration Cancelled Dealers and they were called upon to produce the documents such as Purchase and Sales Bills, Bank Statements, Proof of movement of goods etc. The petitioner sent their explanation dated 25.10.2013, after which one more notice dated 06.12.2013 was issued to the petitioner, in which, there was a proposal to cancel the petitioner's Registration as a dealer. Stating that the petitioner has not given any reply to the notice dated 06.12.2013, the first respondent passed an order on 21.12.2013, confirming the proposal and cancelled the petitioner's Registration Certificate. The said order was put to challenge by the petitioner in W.P.No.350 of 2014, which was allowed by this Court by an order dated 24.09.2014. As the petitioner's Registration was not restored, the petitioner initiated Contempt Proceedings and only thereafter, the Registration was restored. Thereafter, the petitioner was issued with notices of personal hearings on 02.03.2015, 11.3.2015 and 30.03.205. Though the petitioner appeared for personal hearings and submitted their reply on 10.04.2015, no proposal was made by the respondents as to on what grounds the respondents proposed to revise the total and taxable turnover of the petitioner for those two years. In other words, the entire proceedings which culminated in the impugned orders were initiated pursuant to the order dated 21.12.2013, which was an order cancelling the petitioner's Registration Certificate. As noted above, the order dated 21.12.2013 was set aside by this Court by an order dated 24.09.2014. Thus, it is clear that prior to revising the taxable turnover for the relevant years, there was no show cause notice proposing to revise the turnover. Therefore, the fundamental error committed at the very inception has continued, resulting in an arbitrary order being passed. Further, in the impugned orders, the respondents have taken a stand that details sought for by the petitioner cannot be furnished.
