GST interest recovery requires fresh merits decision after notice and personal hearing where tax stood credited in cash ledger.

Recovery action for alleged GST interest liability was required to be revisited because the dispute centred on whether interest was payable when the tax amounts had already been credited to the petitioner's electronic cash ledger or register. The writ was not treated as a proper mandamus for determination of liability; instead, the respondents were directed to pass a fresh order on merits in accordance with law after issuing notice and granting a personal hearing. The interest amount already recovered was left subject to the final outcome of that reconsideration.

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Issues: Whether the impugned recovery action relating to alleged interest liability under the GST enactments could be sustained, and whether the respondents were required to pass a fresh order after hearing the petitioner.

Analysis: The writ petition was not framed as a proper challenge seeking a mandamus for adjudication of the petitioner's liability to interest. The dispute concerned whether interest was payable when the tax amounts had already been credited in the petitioner's electronic cash ledger or register. In these circumstances, the matter required a fresh decision on merits in accordance with law, after notice and personal hearing, so that the respondents could justify their stand on the alleged interest demand.

Conclusion: The matter was directed to be reconsidered by the respondents by passing a fresh order on merits and after hearing the petitioner; the amount recovered towards interest was left subject to the final outcome.

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