Unreasoned GST assessment order and special audit challenge led to interim stay pending further hearing.

A challenge to a CGST/DGST Section 73 assessment focused on the validity of the special audit process under Section 66, limitation, and the notification issued under Section 168A. The petition also argued that the impugned order was unreasoned because it did not address the reply to the show cause notice and merely stated that the reply was unsatisfactory. At the interim stage, the Delhi HC recorded a prima facie view that the order had not dealt with the contentious issues or the reply, and the impugned order was stayed until the next hearing.

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Issues: Whether the impugned order under Section 73 of the CGST/DGST regime was liable to be stayed at the interim stage on the ground that it was unreasoned and ignored the petitioner's reply, and whether the challenge to the special audit and the related notification raised issues warranting further consideration.

Analysis: The petition assailed the assessment order and the preceding show cause notice, alleging lack of jurisdiction in initiating the special audit under Section 66 of the Central Goods and Services Tax Act, 2017, limitation, and challenge to the notification issued under Section 168A of the Central Goods and Services Tax Act, 2017. At the interim stage, the Court recorded a prima facie view that the impugned order did not deal with the contentious issues or the petitioner's reply and merely stated that the reply was unsatisfactory.

Outcome: The impugned order was stayed till the next date of hearing, and notice was issued with directions for pleadings.

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