Natural justice in GST demand disputes led to remand for fresh adjudication after denial of a meaningful hearing.

A mismatch between the GSTR-3B return and GSTR-1 statement led to a tax demand that was confirmed after the assessee did not respond to the show-cause notice or attend the personal hearing. As the writ petition disclosed circumstances explaining that non-participation, the HC held that a meaningful opportunity to contest liability was warranted. The assessment order was set aside and the matter remanded for fresh adjudication, with liberty to file a reply and a further personal hearing after compliance with the stipulated partial payment condition.

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Issues: Whether the assessment order should be set aside and the matter remanded for fresh consideration after affording the assessee an opportunity to contest the tax demand on merits.

Analysis: The tax demand arose from a mismatch between the GSTR-3B return and the GSTR-1 statement, and the demand had been confirmed because the assessee did not reply to the show cause notice or participate in the personal hearing. The writ petition also disclosed circumstances explaining the non-participation. In these facts, the matter warranted a fresh opportunity to contest the liability, though on terms requiring partial compliance with the disputed demand.

Conclusion: The assessment order was set aside and the matter was remanded for reconsideration, with permission to file a reply and a direction to grant a fresh opportunity, including personal hearing, after the stipulated payment condition was satisfied.

Final Conclusion: The assessee was granted a further opportunity to challenge the tax demand on merits, and the original assessment was reopened for fresh adjudication.

Ratio Decidendi: Where the assessee is denied a meaningful opportunity to contest the demand and the circumstances justify intervention, the Court may set aside the assessment and remand the matter for fresh decision after ensuring compliance with equitable conditions.

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