Natural justice in GST assessment supports writ interference where a filed reply was ignored and no hearing was properly considered.

A GST assessment order can be interfered with in writ jurisdiction despite an alternate remedy where the record shows violation of natural justice. The order was contrary to the material on record because it treated the taxpayer as having filed no reply and not participated in the hearing, even though a response in DRC-06 with comparative statements had been submitted. This showed non-application of mind and justified writ intervention. The impugned order was set aside, and the matter was remitted for consideration of the objections already filed, a reasonable opportunity of hearing, and a fresh order in accordance with law.

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Issues: Whether the impugned GST assessment order could be interfered with in writ jurisdiction despite the availability of an alternate remedy, where the record showed that the taxpayer had filed a reply but the order proceeded as if no reply had been submitted.

Analysis: The order was found to be contrary to the material on record because it recorded non-filing of reply and non-participation in hearing despite the petitioner having submitted a response in DRC-06 with comparative statements. This disclosed non-application of mind and a breach of natural justice. The availability of an appellate remedy was held not to preclude writ interference in a case involving violation of natural justice.

Conclusion: The impugned order was set aside and the matter was remitted to the respondent to consider the objections already filed, afford a reasonable opportunity of hearing, and pass a fresh order in accordance with law.

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