Finality of assessment under Section 17D barred unilateral reopening to enhance liability.

An assessment finalised under Section 17D of the KGST Act by the competent Fast Track Team could not be reopened by the first respondent to enlarge the assessee's liability. The provision contemplates finalisation in the prescribed manner and a limited appellate remedy, which supports the finality of an order once it is acted upon within the statutory scheme. Because the first respondent was not part of the original finalisation, he had no authority to vary its scope on his own accord. The subsequent order enhancing liability was therefore inconsistent with the statutory finality attached to Section 17D and was set aside.

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Issues: Whether an assessment finalized under Section 17D of the KGST Act could be reopened by the first respondent to enhance the liability, and whether the subsequent order was liable to be set aside.

Analysis: Section 17D contemplates finalization of the proceedings by the Fast Track Team in the manner prescribed and provides a limited appellate remedy under subsection 5, which reinforces the finality attached to an order passed under that provision when acted upon in the manner contemplated. Once the assessment had been finalized by the competent team, it was not open to the first respondent, who was not part of that order, to vary the scope and extent of liability on his own accord. A subsequent order enlarging the liability was therefore inconsistent with the finality built into the statutory scheme.

Conclusion: The reopening was impermissible and the impugned order enhancing the liability was set aside in favour of the assessee.

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