Reasoned adjudication required under GST law when rejecting an assessee's reply; cryptic orders cannot stand.

An adjudication order under the WBGST Act was unsustainable where the authority failed to consider the assessee's reply to the show-cause notice and gave no reasons for rejecting it. As the first authority in the statutory hierarchy, it was required to evaluate the reply, documents and submissions, and to record reasons showing application of mind. A cryptic statement that the reply was unsatisfactory did not meet this standard. The order was set aside and the matter remanded for fresh adjudication after affording a hearing and considering the material placed by the assessee.

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Issues: Whether the adjudication order passed under section 73 of the WBGST Act, 2017 was liable to be set aside for failure to consider the assessee's reply and record reasons, and whether the matter was required to be remanded for fresh adjudication.

Analysis: The adjudicating authority, being the first authority in the statutory hierarchy, was required to consider the reply to the show-cause notice and state reasons for rejecting it. The impugned adjudication order contained only a cryptic rejection of the reply as unsatisfactory and did not disclose any consideration of the materials or submissions placed by the assessee. The absence of such reasoning rendered the adjudication unsustainable and justified setting aside the order with a direction for fresh consideration.

Conclusion: The adjudication order was set aside and the matter was remanded to the adjudicating authority for fresh consideration after affording opportunity of hearing and considering the reply, documents, and oral submissions.

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