Conditional relief against GST orders granted on deposit, with fresh adjudication directed after reply and personal hearing.

Belated challenge to GST orders was entertained only on a conditional basis because the taxpayer had not replied to the show cause notice and had allowed the appellate limitation period to lapse. The court required deposit of 25% of the disputed tax within 30 days; on compliance, the impugned orders would stand quashed, be treated as an addendum or corrigendum to the show cause notice, and the taxpayer would have 30 days to file a reply. Fresh adjudication on merits, after personal hearing, was then to follow. If the condition was not met, the respondent could enforce the impugned orders.

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Issues: Whether the impugned GST orders, challenged belatedly despite the availability of an appellate remedy, should be quashed on condition of deposit and the matter sent back for fresh adjudication.

Analysis: The petitioner had not replied to the show cause notice and had also allowed the appellate limitation period to lapse. Even so, the Court followed the course adopted in similar matters and granted conditional relief. It directed deposit of 25% of the disputed tax within 30 days, upon which the impugned orders would stand quashed and be treated as an addendum or corrigendum to the show cause notice. The petitioner was then required to submit a reply within 30 days, and the respondent was directed to pass a fresh order on merits after personal hearing. If the condition was not complied with, the respondent was at liberty to enforce the impugned orders.

Conclusion: The impugned orders were set aside conditionally and the matter was remitted for fresh consideration on merits, subject to deposit and filing of reply.

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