GST exemption dispute at show cause stage left to assessing authority after reply and hearing were already provided.

At the show cause notice stage, the Court declined to decide the petitioner's claimed GST exemption itself, holding that the question required examination of the notices, reply, evidence, documents and applicable notifications by the assessing authority. Because the petitioner had already filed a detailed reply and been heard, the Court found no basis to interrupt the ongoing adjudicatory process. It directed the assessing authority to consider all contentions and materials and to drop the notice if exemption was established.

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Issues: Whether the Court should interfere at the stage of the show cause notice and decide the petitioner's claim of exemption from GST, or leave the issue to be determined by the assessing authority.

Analysis: The petitioner's challenge was founded on the claim that its supplies were exempt and that the show cause notice reflected a pre-decided approach. The Court noted that the petitioner had already submitted a detailed reply and had been afforded an opportunity of hearing. The question whether the supplies received or made by the petitioner were exempt from GST required examination of the notices, reply, evidence, documents, and applicable notifications by the assessing authority. In these circumstances, the Court found no reason to interrupt the ongoing adjudicatory process. It directed the assessing authority to consider all arguments and materials, and to drop the notice if exemption was established.

Conclusion: The Court declined to interfere with the show cause proceedings and left the exemption question for decision by the assessing authority.

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