Natural justice in GST assessments: orders quashed and remitted for fresh consideration after opportunity of hearing.

Assessment orders under the Tamil Nadu GST regime were set aside where the petitioner said the prior notices and orders had gone unnoticed and that the statutory appeal remedy under Section 107 was time-barred. The Court accepted the request for a fresh hearing, noted the petitioner's willingness to deposit 10% of the disputed tax, and interfered with the impugned orders to ensure an effective opportunity of reply and hearing. The matter was remitted for fresh consideration and fresh orders after considering the petitioner's response.

---

---

Issues: Whether the impugned assessment orders were liable to be quashed and the matter remitted for fresh consideration on account of the petitioner's claim that the notices and orders had gone unnoticed and that the statutory appeal remedy was time-barred.

Analysis: The Court recorded the petitioner's willingness to deposit 10% of the disputed tax as a condition for rehearing. It also noted the submission that the notices preceding the impugned orders and the orders themselves had gone unnoticed, and that an appeal under Section 107 of the Tamil Nadu Goods and Services Tax Act, 2017 would be barred by limitation. In view of these submissions, the Court interfered with the impugned orders and directed a fresh decision after affording an opportunity to the petitioner.

Conclusion: The impugned orders were quashed and the matter was remitted to the respondent to pass fresh orders after considering the petitioner's reply and hearing the petitioner.

---