Natural justice in GST adjudication requires a proper show cause notice and effective hearing before demand enforcement.

Adjudication under the Jharkhand Goods and Services Tax Act was held unsustainable where Form GST DRC-01 did not meaningfully specify the personal hearing particulars and the taxpayer was not given an effective opportunity to respond. The court treated the defect as substantive, not technical, because the statutory hearing and notice requirements, together with natural justice, were not complied with before the demand was enforced through garnishee action. The adjudication orders and consequential demand notices were quashed, and the matter was remitted for a fresh show cause notice and reconsideration after due hearing.

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Issues: Whether the adjudication orders and consequential demand notices under the Jharkhand Goods and Services Tax Act, 2017 were liable to be quashed for want of a proper show cause notice and denial of personal hearing, and whether the matter required remand for fresh adjudication.

Analysis: The record showed that although inspection and summons proceedings were undertaken, the notice issued in Form GST DRC-01 did not specify the date, time, or venue of personal hearing and recorded the hearing particulars as not applicable. The subsequent adjudication was passed without a meaningful opportunity to respond, and the demand was thereafter enforced through garnishee action. The defect was not merely technical: the statutory procedure under the Jharkhand Goods and Services Tax Act, 2017, especially the requirements governing adjudication and opportunity of hearing, was not followed. The notice could not be treated as a valid substitute for a proper show cause notice, and the proceedings were inconsistent with settled principles of natural justice.

Conclusion: The adjudication orders and consequential Form GST DRC-07 notices were quashed, and the matter was remitted to the adjudicating authority to issue a fresh show cause notice and decide the matter afresh after giving due opportunity to the petitioner.

Ratio Decidendi: A tax adjudication is unsustainable where the statutory notice and hearing requirements are not meaningfully complied with, because a summary form cannot replace a proper show cause notice and an effective opportunity of hearing.

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