Natural justice in GST assessment: fresh hearing granted after notice lapse and mismatch-based demand was remanded for reconsideration.

A GST assessment based on return mismatch was set aside where the demand had been confirmed for non-production of supporting documents, but the petitioner had not been given a reasonable opportunity to contest the proposal on merits. The court accepted that the petitioner's non-participation stemmed from lack of awareness of the later notice, and noted that revenue interest was safeguarded by amounts already recovered and the partial pre-deposit. The matter was remanded for fresh consideration, with liberty to file a reply and receive a personal hearing, and the bank attachment was lifted.

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Issues: Whether the tax demand confirmed for non-production of supporting documents required interference on the ground that the petitioner was not afforded a reasonable opportunity to contest the proposal on merits.

Analysis: The impugned assessment was based on mismatch in GST returns and was confirmed because supporting documents were not furnished. The Court accepted the petitioner's grievance that non-participation in the proceedings was attributable to lack of awareness of the later notice and noted that revenue interest stood secured in view of the amounts already recovered and the partial pre-deposit. In these circumstances, the petitioner was held entitled to a further opportunity to respond and be heard before a fresh decision.

Conclusion: The assessment order was set aside, the matter was remanded for fresh consideration, the petitioner was permitted to file a reply and receive a personal hearing, and the bank attachment was lifted.

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