The AO made an addition under section 69 of the difference between the invoice value of imports as per data received from CBEC and imports disclosed by the assessee in the return of income. The addition was made in the assessment order passed without furnishing the requested break-up of alleged discrepancy and without granting personal hearing. The assessee challenged the addition by filing a writ on the ground of violation of principles of natural justice. The High Court allowed the writ, holding that it is impossible for the Petitioner to reconcile and/or explain the alleged difference between the figures of imports as per the ITR/accounts of the Petitioner, and the data of the CBEC, in the absence of complete details of the break-up of the CBEC data being furnished to the Petitioner. Hence, the order passed was quashed and set aside. The matter was remanded to the AO with directions to issue fresh show cause, provide the detailed break-up of the import value of purchases including the copy of information as received from CBEC and grant sufficient time as well as personal hearing to the assessee before passing the order on or before 31.03.2026. (AY. 2020-21)