Natural justice in GST adjudication requires granting the third personal hearing when expressly sought before final order.

An assessment order passed after a GST DRC-01 notice was challenged for breach of natural justice because the assessee had filed a reply and specifically sought a third personal hearing to produce documents. The court noted that the governing procedure contemplated up to three personal hearings, and once the final hearing was expressly requested, the authority was bound to grant it before adjudication. The impugned order was set aside and the matter was remitted for a personal hearing and fresh orders on merits in accordance with law.

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Issues: Whether the assessment order passed pursuant to the GST DRC-01 notice was liable to be set aside for failure to grant the third personal hearing sought by the assessee.

Analysis: The assessee had filed a reply and sought further time for personal appearance and production of documents, but the authority proceeded to pass the impugned order without affording the final hearing. The provision governing the notice and hearing contemplated a maximum of three personal hearings, and when the assessee specifically requested the third hearing, the authority was bound to provide that final opportunity before adjudication.

Conclusion: The impugned order was set aside and the matter was remitted to the authority for granting a personal hearing and passing fresh orders on merits in accordance with law.

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