Reasoned GST assessment orders must address taxpayer objections; a cursory rejection without independent reasoning is unsustainable.

A GST assessment order under Section 73(9) of the CGST Act cannot stand where it merely states that the reply is unsatisfactory and ignores the taxpayer's explanation and objections. A reasoned decision must deal with the material placed before the authority and disclose application of mind; a demand confirmed without substantive discussion of the issues raised is procedurally defective. On that basis, the Delhi High Court treated the impugned order as unsustainable and quashed it, while leaving the competent authority free to decide the show cause notice afresh.

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Issues: Whether the impugned assessment order under Section 73(9) of the Central Goods and Services Tax Act, 2017 was sustainable when it contained only a cursory rejection of the reply and no substantive reasons.

Analysis: The authority merely recorded that the reply was not satisfactory and that the taxpayer had not attended the personal hearing, but did not engage with the explanation furnished in response to the show cause notice or provide any independent reasoning on the issues raised. An order that confirms demand without any real discussion of the material or the objections raised cannot be sustained, as it fails to disclose application of mind and is inconsistent with the requirement of a reasoned decision.

Conclusion: The impugned order was held unsustainable and was quashed, with liberty to the competent authority to decide the show cause notice afresh.

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