Natural justice in GST assessment requires a personal hearing before final adjudication and fresh consideration on merits.

An assessment challenged for want of personal hearing under GST natural justice principles was treated as requiring fresh consideration on merits. The text notes that part payment had already been made and the dispute concerned input tax credit mismatch, so the matter was sent back for reconsideration after deposit of the balance disputed tax. The operative effect was that the assessment was not left final in its existing form, and the respondent was directed to decide the matter afresh after giving the assessee an opportunity of hearing.

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Issues: Whether the assessment order required interference for want of personal hearing and whether the matter should be sent back for fresh consideration on merits after payment of the balance disputed tax.

Analysis: The impugned assessment was challenged on the ground that it was passed without affording a personal hearing and was said to be contrary to the requirements of natural justice under Section 75 of the GST enactments. The record also showed partial payments already made by the petitioner and the dispute was stated to relate to mismatch of input tax credit. In these circumstances, the Court found it appropriate to direct a fresh decision on merits, with an opportunity of hearing, after deposit of the balance disputed tax.

Conclusion: The matter was directed to be reconsidered by the respondent afresh on merits after the petitioner deposits the balance disputed tax and is given a hearing.

Final Conclusion: The writ petition was disposed of by setting aside the immediate finality of the assessment and remitting the matter for fresh adjudication in accordance with law.

Ratio Decidendi: Where an assessment is alleged to have been completed without personal hearing, the Court may direct fresh adjudication on merits with an opportunity of hearing, particularly when the dispute can be reconsidered after the assessee makes the required deposit.

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