Natural justice in GST adjudication requires personal hearing and supply of relied upon documents before adverse demand action.

Under GST procedure, an adverse adjudication cannot be sustained where the taxpayer was not given a personal hearing and the relied upon documents were not supplied. The text states that a reply date in the show cause notice did not amount to a fixed hearing date, and the absence of both hearing and document disclosure breached the statutory procedure and principles of natural justice. On that basis, the adjudication order and consequential demand notices were quashed, and the matter was remitted for fresh notice, supply of documents, personal hearing, and reconsideration in accordance with law.

---

---

Issues: Whether the adjudication order and consequential demand notices were liable to be quashed for breach of the statutory requirement of personal hearing and non-supply of relied upon documents.

Analysis: The writ arose from proceedings under the goods and services tax law where the assessee complained that no personal hearing was granted before the adverse adjudication order was passed and that the relied upon documents were not supplied. The record showed that although a reply date was mentioned in the show cause notice, no date for personal hearing was fixed before final adjudication. The decision relied on the settled interpretation of the statutory scheme requiring hearing where an adverse decision is contemplated and where the person chargeable with tax seeks an opportunity. On the admitted facts, the absence of personal hearing and denial of access to relied upon documents amounted to non-compliance with the statutory procedure and the principles of natural justice.

Conclusion: The adjudication order and consequential demand notices were quashed, and the matter was remitted for a fresh notice, supply of relied upon documents, personal hearing, and reconsideration in accordance with law.

---