GST assessment disputes over input tax credit, show-cause notice mismatch, and alleged employee-linked registrations; writ quash refused.

The dominant issue was whether writ jurisdiction should be exercised to quash GST assessment orders on alleged violation of natural justice and errors affecting input tax credit. On the discrepancy between the show cause notice and the impugned order, the HC held that the record disclosed an arguable basis that the notice reflected a typographical error (showing CGST liability as nil) when read as a whole, and no conclusive finding was warranted in writ; interference was declined. On transitional ITC, the HC held that the assessee bears the burden to prove entitlement and the assessing officer may call for further documents; this did not justify writ interference. Allegations of registrations in employees' names for wrongful ITC did not, cumulatively, establish grounds to invoke discretionary jurisdiction; the writ petitions were dismissed with liberty to file statutory appeals.

---

---

Issues involved:
The judgment deals with challenges to separate assessment orders dated 06.10.2023 on three grounds: discrepancy in specified sums, transitional credit eligibility, and denial of documents and cross-examination rights.

Discrepancy in specified sums:
The petitioner contested that the sum specified in the show cause notice differed from the sum in the impugned order, particularly regarding CGST liability. The respondent argued that the show cause notice indicated the liability to pay CGST, despite a typographical error showing zero liability. The Court noted the discrepancy but did not reach conclusive findings, suggesting a typographical error.

Transitional credit eligibility:
The impugned orders required the taxpayer to provide additional documents to verify the claim for transitional Input Tax Credit (ITC). The petitioner asserted that all necessary documents were submitted and self-explanatory. The Court held that if the assessing officer deemed further documents necessary, it did not warrant interference in discretionary jurisdiction.

Denial of documents and cross-examination rights:
The petitioner argued that they were not provided with all relied-upon documents or allowed to cross-examine relevant parties. The respondent contended that ITC was unlawfully availed of, including through employees, based on intelligence reports. The Court emphasized the taxpayer's responsibility to establish eligibility for ITC and found no grounds for exercising discretionary jurisdiction based on the denial of documents and cross-examination rights.

Conclusion:
The Court dismissed all writ petitions, allowing the petitioner to challenge the orders through statutory appeals. It directed the appellate authority to consider the appeals independently of the judgment. No costs were awarded, and connected Miscellaneous Petitions were closed.

---