Natural justice requires disclosure of foundational material before GST adjudication and rehearing after supply of the report.

An appellate order under the West Bengal GST Act was set aside for breach of natural justice because the demand rested on a foundational report that had not been furnished to the petitioner. The court held that, where such material forms the basis of adjudication, fairness requires disclosure so the affected party can effectively meet it. The appeal was directed to be reheard after supplying the report to the petitioner.

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Issues: Whether the appellate order under the West Bengal Goods and Services Tax Act, 2017 was liable to be set aside for failure to supply the foundational report relied upon in adjudication, and whether the appeal was required to be reheard after furnishing that material to the petitioner.

Analysis: The appellate and adjudicatory orders rested on a report of the Irrigation and Waterways Directorate, which formed the foundation of the demand. The Revenue could not show that the report had ever been furnished to the petitioner. Since the report was central to the adjudication, fairness required that the petitioner be given a copy so that the substance of the material could be effectively met.

Conclusion: The appellate order was set aside for breach of natural justice, and the appellate authority was directed to rehear the appeal after supplying the report to the petitioner.

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