Natural justice in GST penalty proceedings requires a meaningful hearing, not a same-day reply and personal hearing notice.

Fixing the same date for filing a reply and for personal hearing in GST penalty proceedings can amount to denial of a reasonable opportunity to be heard and a breach of natural justice. Where the notice does not give the assessee a meaningful chance to respond before the matter is decided, the resulting penalty order and any appellate order are liable to be set aside and the matter remanded for fresh adjudication after proper hearing.

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Issues: Whether the assessment proceedings were vitiated because the date fixed for filing reply and the date fixed for personal hearing in the show cause notice were the same, thereby denying proper opportunity of hearing under the GST penalty proceedings.

Analysis: The notice fixed 17.9.2024 both for filing the reply and for personal hearing. This was treated as an inadequate opportunity, since the assessee was required to have a meaningful chance to respond before the matter was decided.

Conclusion: The order imposing penalty and the appellate order were quashed, and the matter was remanded for fresh consideration after granting proper opportunity of hearing to the petitioner.

Final Conclusion: The writ petition succeeded on the ground of denial of proper hearing, and the proceedings were sent back for fresh adjudication in accordance with law.

Ratio Decidendi: Fixing the same date for submission of reply and personal hearing in penalty proceedings amounts to denial of reasonable opportunity and violates the principles of natural justice.

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