GST demand on unreconciled turnover set aside conditionally, with fresh opportunity and personal hearing directed on compliance terms.

An assessment order confirming GST demand on unreconciled turnover was set aside conditionally because the taxpayer had not earlier responded, yet claimed the mismatch could be explained by completion certificates and reconciliation records. The court treated the dispute as one warranting a further opportunity, but required the taxpayer to comply with terms before reconsideration. The taxpayer was directed to remit Rs.50,00,000 and file a reply with supporting documents, and the authority was directed to provide a reasonable opportunity, including personal hearing, before passing a fresh order.

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Issues: Whether the assessment order confirming the GST demand for unreconciled turnover was liable to be set aside for want of a proper opportunity, and whether the matter should be remitted for fresh consideration on terms.

Analysis: The impugned order proceeded on the basis that the petitioner had not responded to the show cause notice and reminders. At the same time, the petitioner asserted that the unreconciled turnover could be explained by supporting documents, including completion certificates and reconciliation material. In the circumstances, the dispute was treated as one in which another opportunity was warranted, but the petitioner's failure to respond earlier justified putting it on terms.

Conclusion: The impugned order was set aside conditionally, the petitioner was directed to remit Rs.50,00,000/- and submit a reply with supporting documents, and the respondent was directed to afford a reasonable opportunity including personal hearing and pass a fresh order.

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