Natural justice challenge to GST assessment failed where notice was served, a reply was filed, and no personal hearing was sought.

A writ challenge to a GST assessment order was rejected where the taxpayer had received notice under Rule 100 of the Tamil Nadu GST Rules, filed a merits-based reply, and did not seek or avail personal hearing. On those facts, the complaint of denial of opportunity was not accepted, and no infirmity in the assessment under Section 61 of the Tamil Nadu GST Act, 2017 was shown. The High Court declined to entertain the writ petition, dismissed it, and left the taxpayer to pursue the statutory appellate remedy, with the impugned order standing.

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Issues: Whether the writ petition challenging the GST assessment order was maintainable on the ground that no opportunity of hearing was afforded to the petitioner.

Analysis: The impugned order was passed under Section 61 of the Tamil Nadu Goods and Services Tax Act, 2017 pursuant to notice under Rule 100 of the Tamil Nadu Goods and Services Taxes Rules, 2017. The petitioner had received the notice and filed a reply on merits, but did not seek or avail a personal hearing. In these circumstances, the complaint of denial of opportunity could not be accepted, and no infirmity in the impugned order was shown.

Conclusion: The writ petition was not entertained and was dismissed.

Final Conclusion: The petitioner was left to pursue the statutory appellate remedy, and the impugned GST order was allowed to stand.

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