GST demand orders must be self-contained and reasoned; a non-speaking order incorporating the notice by reference was quashed.

An undated GST demand order under Section 73 was held unsustainable because it merely incorporated the show cause notice by reference and did not record independent reasons, relevant facts, or the basis of decision required by Section 75(6). A final adjudicatory order under the GST law must be self-contained and disclose the reasoning process; failure to do so renders it legally invalid. The demand order was quashed and the matter remitted for fresh decision after giving the taxpayer an opportunity to respond and be heard.

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Issues: Whether an undated demand order passed under Section 73 of the Goods and Services Tax Act, 2017, which merely incorporates the show cause notice by reference and does not set out relevant facts or the basis of decision as required by Section 75(6), could be sustained.

Analysis: The order did not record any independent reasons and only reproduced the contents of the show cause notice by reference. A final adjudicatory order under the GST law must be self-contained and must set out the relevant facts and the basis of the decision. Absence of such reasoning renders the order legally unsustainable.

Conclusion: The impugned demand order could not be sustained and was quashed, with the matter remitted for fresh decision after opportunity of response and hearing.

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