JUDGMENT :

CHIEF JUSTICE (ACTING), J.

1. Heard Ms. Nitu Hawelia and Ms. Medha Lila Gope, learned counsel assisted by Ms. Simita Chakraborty learned counsel appearing for the petitioner. Also heard Mr. S.S. Dey, learned Advocate General assisted by Mr. K. De, learned Addl. G.A. appearing for the Respondents.

2. The petitioner has filed the instant petition challenging the impugned orders of assessment and demand notice dated 26.03.2021 for the assessment years 2015-16, 2016-17 and 2017-18 (Annexure VII) under the TRIPURA VALUE ADDED TAX ACT , 2004.

3. The petitioner is a dealer dealing in Electrical goods, Electronic goods, furniture and parts, Floor covering, kitchenware, Marble & Articles of Marble, Mosaic tiles, Chips & Powder Plywood, Veneer Plywood, Paints, Lacquers, Polishes, Enamels, Colours, Varnishes, Primers of all kinds, Air Conditioning plants, Air Conditioner parts & accessories in the State of Tripura. The petitioner also deals in parts and accessories. For the assessment years 2015-16 to 2017-18, the petitioner has filed his return of turnover in the State of Tripura along with all papers and documents. Thereafter there was no notice from the respondent state tax department and the petitioner for all intent and purpose was sure that the returns for the said years have been accepted along with papers and documents. However, all on a sudden, during the COVID period the respondent issued a show cause notice dated 24.09.2020 is suppression of previous notice issued under Section 31 of the TRIPURA VALUE ADDED TAX ACT , 2004 on the ground that the petitioner was selected for audit assessment.

4. The petitioner has filed a reply dated 06.10.2020 along with photocopies of the documents. However the Respondent No. 3 was not satisfied with the same and on the basis of suspicion and surmises, asked the petitioner to produce the original invoices. Since it was COVID period, the petitioner asked for four months time to bring and produce the original invoices which were at Mumbai and was badly hit by COVID. However, the respondent No. 3 without waiting for the invoices vide the assessment orders dated 26.03.2021, a demand notice was passed and order of assessment for the assessment years 2015-16 to 2017-18 issued notices of demand for the said years.

5. The petitioner have challenged the impugned orders of assessment dated 26.03.2021 for the assessment years 2015-16 to 2017-18 under the TRIPURA VALUE ADDED TAX ACT , 2004 on the ground that all reasonable opportunities of hearing were granted to the petitioner before passing of the said assessment order. The petitioner therefore prayed for setting aside the impugned orders of assessment and notice of demand dated 26.03.2021 for the assessment years 2015-16 to 2017-18.

6. Ms. Nitu Hawelia, learned counsel appearing for the petitioner has contended that sufficient opportunity have not been given. Providing of opportunity must be real and effective to term the said opportunity as reasonable opportunity of being heard. The opportunity should not merely be on papers, but must actually be provided to the dealers. It was further argued by the learned counsel that taxing laws are to be interpreted very strictly. There is no intendment as to taxation, nothing is to be read and nothing is to be left out. The word in taxing statutes are interpreted with full meaning given to each and every word of the statute. In the instant case when the legislatures have used the word “reasonable opportunity of hearing” under Section 31 of the TRIPURA VALUE ADDED TAX ACT , 2004, the word “reasonable” have to be given its due meaning and cannot be brushed aside. It is not sufficient