ORDER V. RAMASUBRAMANIAN, J. - By the proceedings of the second respondent dated October 30, 2000 the petitioner was finally assessed for a total and taxable turnover for the year 1999-2000, on self-assessment basis. In the self assessment, the petitioner disclosed an inter-State purchase of chemicals effected from other State dealers, in a particular amount. However, on the basis of a counter check of the transactions mentioned in the "C" form, made by the second respondent through the inter-State Investigation Cell of Mumbai city, the second respondent reopened the assessment and issued a pre-revision notice dated February 21, 2005. The petitioner requested the respondent to produce the copies of the documents available with the second respondent to enable him to file a detailed objection. However, the second respondent passed an order dated June 21, 2007, holding that as per the extract and copy of the bogus "C" form, the petitioner had purchased the chemicals from Mumbai dealers. The second respondent also recorded that the purchase details, namely, invoice number, date and value had already been issued in the pre-revision notice and that the burden of proof lies on the petitioner to establish that he did not have the transactions with the Mumbai dealer. Aggrieved by the said order, the petitioner has come up with the present writ petition. Heard Mr. P. Rajkumar, the learned counsel for the petitioner and Mr. Pala Ramasamy, the learned Special Government Pleader, for the respondents. It is seen from the impugned order that the second respondent has taken a stand that the purchase details such as invoice number, date and value, etc., had already been furnished in the pre-revision notice itself and that the burden of proof was on the dealer to show that he did not have such transactions. In my considered view, such a stand is not actually sustainable. It is not enough for the second respondent to merely furnish the purchase details like invoice number, date, value, etc., in the pre-revision notice. It is incumbent upon the second respondent to also furnish the copies of the documents on the basis of which the assessment was reopened. Furnishing copies of the documents, which form the basis for reopening the assessment, is different from merely furnishing details in the pre-revision notice. Moreover, the burden of proof cannot be shifted to establish the negative. It is incumbent upon the second respondent to also furnish the copies of the documents on the basis of which the assessment was reopened. Furnishing copies of the documents, which form the basis for reopening the assessment, is different from merely furnishing details in the pre-revision notice. Moreover, the burden of proof cannot be shifted to establish the negative. In this case, the second respondent has imposed an obligation upon the petitioner to prove the negative, namely, that the petitioner did not make the transactions in question. Therefore, the writ petition is ordered setting aside the impugned order and directing the second respondent to provide the copies of whatever documents he has in his possession for passing the order impugned in the writ petition, to the petitioner within a period of two weeks. If the second respondent is not in possession of any of the documents, the second respondent shall also intimate the same to the petitioner. In other words, the second respondent shall send a letter to the petitioner enlisting the list of documents available with him and enclosing the copies of such documents which form the basis of his impugned order. After forwarding such a letter enclosing copies of the available documents, the second respondent shall give an opportunity to the petitioner to challenge those documents in accordance with law and thereafter, pass fresh assessment orders. The writ petition is disposed of with the above direction. No costs. Consequently, connected miscellaneous petition is closed.