Conflicting GST assessment orders were set aside and remitted for fresh consideration after later orders dropped most issues.

Conflicting GST assessment orders under the Tamil Nadu GST Act could not be sustained when later orders on the same issues had already dropped most matters. The court held that the earlier demand and consequential rectification order required fresh examination in light of those subsequent orders and after giving the taxpayer an opportunity of hearing. The impugned orders were set aside and the proceedings were remitted to the respondent for reconsideration in accordance with the later orders.

---

---

Issues: Whether the assessment orders and the consequential rectification order under Section 161 of the Tamil Nadu Goods and Services Tax Act, 2017 required interference and remand in view of subsequent fresh orders passed on the same subject matter.

Analysis: The impugned assessment orders had confirmed the demand, while later orders passed by the Assistant Commissioner [ST] [IU] dropped most of the issues. In view of the existence of two sets of orders from different authorities on the same issues, the earlier orders could not be sustained without reconsideration. The matter therefore required fresh examination by the respondent after considering the later orders and after affording the petitioner an opportunity of hearing.

Conclusion: The impugned orders were set aside and the matters were remitted to the respondent for fresh orders.

Final Conclusion: The writ petitions succeeded and the assessment proceedings were sent back for reconsideration in accordance with the later orders and after hearing the petitioner.

Ratio Decidendi: Where conflicting orders exist on the same tax issues, the earlier demand order may be set aside and the matter remitted for fresh decision after due hearing and consideration of the later orders.

---