Natural justice breach under GST led to quashing of the assessment order and the consequential appellate dismissal.

An order passed under the GST regime was held non est because the petitioner was not afforded an effective opportunity of hearing, amounting to violation of natural justice. The consequential appellate order, which dismissed the appeal as time-barred, also could not survive once the order was invalid. The HC quashed both orders and directed the authorities to grant a fresh hearing and then pass a new order in accordance with law.

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Issues: Whether the order passed under Section 73 of the GST regime and the consequent appellate order dismissing the appeal as time-barred could be sustained when no effective opportunity of hearing was afforded to the petitioner.

Analysis: The record showed issuance of notice with dates for reply and personal hearing, but the petitioner was not granted a further opportunity before the order dated 15.02.2025 was passed. The Court found the matter covered by prior coordinate bench authority and held that the original order suffered from violation of natural justice and was therefore non est in law. The appellate order dated 29.09.2025, being consequential, could not survive.

Conclusion: The orders dated 15.02.2025 and 29.09.2025 were quashed and set aside, and the authorities were directed to grant another opportunity of hearing and thereafter pass a fresh order in accordance with law.

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