Natural justice in GST adjudication requires a meaningful hearing before Section 73 orders are finalised.

An order under Section 73 of the Odisha GST Act was held unsustainable where the adjudicating authority passed it before the expiry of the time sought by the assessee and without ensuring a meaningful opportunity of hearing. A written request for extension of time to file a reply was sufficient; the absence of a specific request for personal hearing did not negate the request for time. The order was quashed and the matter remitted for fresh adjudication after affording the assessee an opportunity of hearing.

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Issues: Whether the order passed under Section 73 of the Odisha Goods and Services Tax Act, 2017 was liable to be quashed for non-grant of opportunity of hearing and for being passed before expiry of the time sought by the assessee.

Analysis: The request for extension of time was made in writing, and the statutory scheme required a meaningful opportunity before final adjudication. The mention of no personal hearing in the time request did not negate the request for time to file reply. The adjudicating authority acted before the expiry of the period sought and without ensuring compliance with the hearing requirement under the statute, rendering the order unsustainable.

Conclusion: The impugned order was quashed and the matter was remitted to the adjudicating authority to proceed afresh after affording opportunity of hearing to the assessee.

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