Self-contained GST adjudication orders must state facts and reasons; a notice-only order was quashed and remanded.

An adjudication order under the Uttar Pradesh GST law was held unsustainable because it did not set out the relevant facts or the basis of decision, instead merely referring to the show cause notice and recording non-response. The HC noted that Section 75(6) requires the proper officer to state the relevant facts and the basis of the decision, and that a final order must be self-contained. Mere reproduction of the notice, even without a reply, does not satisfy that requirement. The order was quashed and the matter remanded for fresh adjudication after opportunity of reply and hearing.

---

---

Issues: Whether the adjudication order passed under Section 73 of the Uttar Pradesh Goods and Services Tax Act, 2017 was vitiated for want of relevant facts and the basis of decision, and whether the matter was liable to be remanded for fresh adjudication after opportunity of reply and hearing.

Analysis: The impugned order merely referred to the notice, recorded non-response, and raised demand, without setting out the relevant facts or the basis of the decision. Section 75(6) of the Uttar Pradesh Goods and Services Tax Act, 2017 requires the proper officer to state the relevant facts and the basis of his decision, and a final adjudication order must be self-contained. Mere reproduction of the show cause notice, even if no reply was filed, does not satisfy the statutory requirement.

Conclusion: The order was unsustainable for non-compliance with Section 75(6) of the Uttar Pradesh Goods and Services Tax Act, 2017 and was liable to be quashed. The matter was remanded for filing of response and for passing of a fresh order after hearing.

Final Conclusion: The assessee succeeded in obtaining quashing of the adjudication order, and the matter was sent back for fresh adjudication in accordance with law.

Ratio Decidendi: An adjudication order under the goods and services tax law must disclose the relevant facts and the basis of decision, and an order that merely reproduces the show cause notice without independent reasoning is not a valid self-contained order.

---