GSTIN reconciliation dispute led to remand for fresh adjudication after denial of effective hearing

Reconciliation of tax credit and TDS deposited under the wrong GSTIN required a fresh adjudication because the assessee had not been given an effective opportunity to present its case. The court noted that additional documents could be considered for a comprehensive determination, so the demand order could not be sustained on the existing record. The impugned order was set aside and the matter was remitted to the adjudicating authority for fresh adjudication after hearing the assessee.

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Issues: Whether the impugned order raising demand could be sustained, or whether the petitioner was entitled to an opportunity before the adjudicating authority in view of the reconciliation issue concerning TDS deposited under the wrong GSTIN.

Analysis: The dispute concerned reconciliation of tax credit and TDS deposited by clients in an incorrect GST registration number. As the petitioner had not been afforded an effective opportunity to present its case before the adjudicating authority, and additional documents could be considered for a comprehensive adjudication, the matter warranted re-examination in the interest of justice.

Conclusion: The impugned order was set aside and the petitioner was directed to appear before the adjudicating authority for fresh adjudication.

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