Natural justice in assessment proceedings requires a real opportunity to reply before finalisation; matter remanded for fresh consideration.

An assessment made without considering the dealer's reply to the show cause notice was set aside because a proper opportunity to be heard had not been afforded before finalisation. The dealer, registered under the composition scheme, had filed GSTR-4 returns belatedly, and the matter was affected by closure of business and the proprietor's asserted ill-health. In these circumstances, the Court found that the interests of justice required one more chance to submit the reply and supporting documents. The matter was remanded for fresh assessment after issuance of notice, receipt of the reply and documents, and a personal hearing.

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Issues: Whether the impugned assessment order was liable to be set aside and the matter remanded for fresh consideration after granting an opportunity to file reply and produce supporting documents.

Analysis: The petitioner was treated as a dealer under the composition scheme and had filed returns in GSTR-4, though belatedly. The controversy arose because the assessment was completed after non-filing of a reply to the show cause notice. Considering the closure of business, the asserted ill-health of the proprietor, the delay in compliance, and the need to afford a proper opportunity before finalising the assessment, a further chance to respond was warranted in the interest of justice.

Conclusion: The impugned order was set aside and the matter was remanded to the authority for fresh assessment after issuing notice, receiving the reply and documents, and granting personal hearing.

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