GST rectification requests must be reasoned and heard before rejection, with fresh consideration required where apparent error is alleged.

A rectification request under Section 161 of the Tamil Nadu GST Act must be examined on its merits when an apparent error on the record is alleged. A refusal to entertain the application cannot stand unless it gives reasons and addresses the specific error pointed out. Where the proviso contemplates hearing, the applicant must be afforded that opportunity before disposal. On that basis, the rejection of the rectification application was set aside, the matter was remitted for fresh consideration, and the consequential DRC-07 proceedings were kept in abeyance.

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Issues: Whether the rejection of the rectification application under Section 161 of the Tamil Nadu Goods and Services Tax Act, 2017, was sustainable and whether the matter required reconsideration with an opportunity of hearing.

Analysis: The rectification order contained no reasons and did not consider the specific error pointed out in the return. In proceedings under Section 161, an application alleging an apparent error on the record must be examined on its merits, and any refusal to entertain such request must be supported by reasons. The absence of a reasoned decision warranted interference. The request for hearing was also relevant, as the proviso contemplated such opportunity before disposal of the application.

Conclusion: The rejection of the rectification application was set aside and the matter was remitted to the first respondent for fresh consideration after hearing the petitioner and recording reasons if the request is declined. The consequential proceedings pursuant to the DRC-07 notice were kept in abeyance.

Final Conclusion: The writ petition succeeded only to the extent of securing reconsideration of the rectification request and interim protection against further proceedings, while the underlying assessment dispute was left open for fresh decision.

Ratio Decidendi: A rectification request under the GST rectification provision cannot be rejected without reasons and without considering the specific error pointed out; if refused, the authority must pass a speaking order after affording hearing where contemplated.

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