Natural justice in GST demand proceedings fails where no reply or hearing request was made, and appeal remedy remains available.

A writ challenge to an ex parte GST demand and section 73 show-cause notice was rejected because the assessee had not filed any reply, sought extension of time, or requested a personal hearing. The Court distinguished prior authority on denial of hearing, noting that in that case a detailed reply and hearing request had been made. On these facts, the plea of breach of natural justice was not accepted, and the assessee was left to pursue the statutory appellate remedy under section 107. The writ petition was therefore not entertained.

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Issues: Whether the writ petition challenging the ex parte demand order and show cause notice under the State Goods and Services Tax Act was maintainable in view of the statutory appeal remedy, and whether denial of personal hearing vitiated the proceedings when the assessee had not filed a reply to the notice under section 73.

Analysis: The petitioner assailed the demand order on the ground that the notice under section 73 did not specify a date, time, or place for hearing. The Court noted from the departmental instructions and pleadings that notices had earlier been issued under section 61, that no reply was filed to the notice under section 73, and that no request for time extension or personal hearing was made. The reliance on the earlier decision dealing with denial of hearing was distinguished on the ground that, in that case, a detailed reply and request for hearing had been made. In the present case, the Court held that where the assessee chose not to respond to the notice, the plea of violation of natural justice could not be accepted, and the petitioner ought to have pursued the statutory appeal under section 107.

Conclusion: The writ petition was not entertained and the challenge based on denial of personal hearing failed; the statutory appellate remedy was held to be available.

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