Natural justice in tax adjudication: failure to consider a filed reply led to quashing and remand for fresh decision.

An adjudication order and consequential DRC-07 were quashed because the authority failed to consider the petitioner's reply to the show cause notice, despite the record showing a detailed reply had been filed in DRC-06 with annexures. That non-consideration amounted to a breach of natural justice, and the respondents could not dispute the factual position. The matter was remitted to the authority to examine the reply, grant a personal hearing, and pass a reasoned order in accordance with law.

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Issues: Whether the impugned adjudication order and consequential DRC-07 deserved to be quashed for non-consideration of the petitioner's reply to the show cause notice and breach of natural justice.

Analysis: The impugned order recorded that no reply had been filed, but the record showed that a detailed reply had in fact been submitted in DRC-06 along with annexures. Since the reply was not considered, the adjudication suffered from violation of natural justice. The respondents were unable to controvert this factual position.

Conclusion: The impugned order was set aside and the matter was remitted to the authority to consider the reply, grant a personal hearing, and pass a reasoned order in accordance with law.

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