Reasonable opportunity in GST adjudication led to conditional remand, with reply, personal hearing, and deposit requirements.

GST demand confirmed without a reply to the show cause notice was set aside because the petitioner was given a credible explanation for non-participation and the interests of justice required reconsideration. The High Court permitted the matter to be reopened on condition of deposit of 10% of the disputed demand, with liberty to file a reply, and directed the authority to afford a reasonable opportunity, including personal hearing, before passing a fresh order. The dispute was therefore remitted for fresh adjudication after compliance with the deposit and hearing requirements.

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Issues: Whether the impugned order confirming the GST demand was liable to be set aside for denial of a reasonable opportunity and the matter remitted for fresh consideration on conditions.

Analysis: The order was passed after the petitioner did not reply to the show cause notice. The Court accepted the explanation that the non-participation was stated to be due to the petitioner not being aware of the proceedings, and considered that the interests of justice warranted reconsideration. Relief was made conditional upon deposit of 10% of the disputed tax demand, with liberty to file a reply and a direction to afford a reasonable opportunity, including personal hearing, before passing a fresh order.

Conclusion: The impugned order was set aside conditionally and the matter was remitted for fresh adjudication after compliance with the directed deposit and hearing opportunity.

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