Conditional GST writ relief granted where taxpayer missed adjudication, with deposit and reply required before fresh scrutiny.

Writ interference in GST assessment and recovery proceedings was declined in a case where the taxpayer had not responded to the show-cause notice or subsequent portal reminders. The Court noted the grievance over the mismatch between the assessment demand and the recovery notice, but treated non-use of the statutory adjudication mechanism as significant. Conditional relief was granted instead of direct appellate redress: the taxpayer was required to deposit part of the disputed tax and file a reply within the stipulated time, failing which the authorities could proceed in accordance with law. On compliance, the impugned order would be quashed and fresh adjudication would follow.

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Issues: Whether the impugned assessment order and consequential recovery action warranted interference in writ jurisdiction, and whether the petitioner could be directed to pursue the statutory adjudication mechanism after compliance with specified conditions.

Analysis: The petitioner did not respond to the show-cause notice or reminders issued through the GST portal. The Court noted the grievance regarding the discrepancy between the demand in the assessment order and the recovery notice, but held that the petitioner had not availed the adjudication mechanism under the GST enactments. In view of the settled approach in similar matters, the Court declined to send the petitioner straight to the appellate remedy at that stage and instead granted conditional relief by requiring deposit of part of the disputed tax and filing of a reply, after which the impugned order would stand quashed and fresh adjudication would follow.

Outcome: Conditional relief was granted. The writ petition was disposed of with directions to deposit 25% of the disputed tax and file a reply within the stipulated time, failing which the respondent was free to proceed in accordance with law.

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