Meaningful opportunity in GST assessment matters required where seized records prevent a reply, leading to remand for fresh disposal.

GST assessment orders may not be sustained where the assessee is unable to file a reply because relevant records are seized by the tax authorities, as a meaningful opportunity to present the defence must be afforded before adverse action is taken. The Madras High Court noted that the impugned order had been passed without allowing the assessee to place its case on record in the absence of seized documents. The order was quashed and the matter remitted for fresh disposal on merits and in accordance with law.

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Issues: Whether the assessment order confirming GST demands could be sustained when the assessee claimed inability to file a reply because the relevant records were seized by the Central Tax Authorities.

Analysis: The assessee's grievance was that the reply to the show cause notice could not be filed in the absence of seized documents, while the respondent proceeded to pass the impugned order. In these circumstances, the order was found to have been passed without affording a meaningful opportunity to place the defence on record, warranting interference and reconsideration.

Conclusion: The impugned order was quashed and the matter was remitted to the respondent for fresh disposal on merits and in accordance with law.

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