Conditional writ remand allowed on merits, with assessment set aside after deposit and fresh reply directions.

Writ jurisdiction was exercised despite objections of delay and an allegedly time-barred statutory appeal because the petitioner was considered to have a possible case on merits. The assessment order was set aside and the matter was remitted for fresh adjudication after the petitioner was directed to file a reply with supporting documents. Relief was made conditional on deposit of 25% of the disputed tax, reflecting a discretionary remand rather than final determination of liability.

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Issues: Whether the assessment order was liable to be set aside and the matter remitted for fresh consideration, subject to conditions, despite the objection of delay and availability of appellate remedy.

Analysis: The petitioner complained that the notices and hearing opportunities were uploaded in the GST portal and were not effectively responded to in time. The respondent objected that the writ petition was barred by delay and that the statutory appellate remedy was time-barred. The Court found that the petitioner may have a case on merits and exercised writ discretion to interfere, while imposing a condition of deposit and directing a fresh reply with supporting documents before reconsideration by the respondent.

Conclusion: The assessment order was set aside and the matter was remitted for fresh adjudication, subject to deposit of 25% of the disputed tax and filing of a reply with documentary evidence.

Final Conclusion: The writ petition was disposed of with a conditional remand for reconsideration on merits, granting partial relief to the petitioner.

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