Natural justice challenge to GST assessment failed where prior notices, replies and hearing opportunity showed adequate disclosure and participation.

A challenge to a GST assessment under Section 74 failed where the show-cause process was read with the earlier pre-notice communication and annexures, which disclosed the supplier identity, transaction details and demand quantification. The Madras High Court held that the assessee was aware of the basis of proceedings from its own replies, had sought time to produce documents, and was offered personal hearing under Rule 142(4) but did not appear. In these circumstances, the Court found no breach of natural justice, held that the assessee had not cooperated in the assessment process, and upheld the assessment order.

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Issues: Whether the assessment order passed under Section 74 was vitiated for want of proper particulars in the show-cause notice and for alleged breach of natural justice, including non-supply of supporting materials and denial of effective opportunity of hearing.

Analysis: The challenge was founded on the contention that the notice under Section 74 did not itself set out the specific transaction and therefore did not enable a proper reply. The Court held that the notice under Section 74 was a continuation of the earlier proceedings initiated through the pre-notice communication and its annexures, which contained the identity of the supplier, the transaction details, and the quantification of demand. It was also found that the assessee was aware of the exact basis of the proceedings from its own replies, sought time to produce supporting documents, and was offered personal hearing under Rule 142(4) of the Tamil Nadu Goods and Services Tax Rules, 2017, but did not appear. In these circumstances, the Court held that the assessee failed to cooperate in the assessment process and that the assessing authority had proceeded on the materials available after affording sufficient opportunity.

Conclusion: The challenge to the assessment order on the ground of violation of natural justice failed, and the assessment was upheld.

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