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Issues: Whether the rejection of the refund claim was sustainable when the reply and rectified FIRC details filed in response to the first show-cause notice were not considered, and whether the matter required remand for fresh consideration.
Analysis: The refund claim was made within the period prescribed under Section 54 of the Central Goods and Services Tax Act, 2017. The petitioner responded to the first show-cause notice by filing rectified FIRC details, but the subsequent notice and the rejection order proceeded as if no reply had been filed and no FIRC details had been produced. The omission to consider the reply disclosed non-application of mind and a failure to adhere to fair procedure. In such circumstances, the proper course was to set aside the rejection and direct reconsideration after notice and personal hearing.
Conclusion: The rejection order was not sustained and the matter was remanded to the authority for fresh decision after considering the petitioner's reply and after granting notice and personal hearing.
Final Conclusion: The writ petition succeeded to the extent of obtaining a fresh adjudication on the refund claim, with the impugned rejection displaced by a remand for decision on merits.
Ratio Decidendi: An order rejecting a refund claim cannot stand where the authority fails to consider a duly filed reply and supporting documents, as such omission amounts to non-application of mind and violates fair procedure.