Natural justice in GST adjudication requires consideration of prior hearing materials; delayed writ remitted with pre-deposit conditions.

Failure to consider a prior personal hearing, filed documents, and objections in GST adjudication vitiates the fairness of the assessment order, so the demand could not stand to that extent. Although the writ was belated and the statutory appeal period had expired, the matter was still remitted for fresh adjudication on merits rather than rejected outright. The remand was made conditional on the assessee depositing 50% of the disputed tax in cash, filing an additional reply with supporting documents, and complying within the stipulated time. On compliance, the bank attachment was to be vacated and the assessment reconsidered afresh.

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Issues: (i) whether the impugned assessment order was liable to be interfered with for violation of natural justice in not considering the earlier personal hearing and materials; (ii) whether the matter should be remanded subject to pre-deposit and other consequential directions.

Issue (i): The impugned order confirmed the demand without dealing with the petitioner's earlier appearance, the documents stated to have been filed, or the objections that may have been raised at the first hearing. In a tax adjudication, failure to advert to a material hearing and the relevant reply materials vitiates the fairness of the decision-making process.

Conclusion: The order was found unsustainable to that extent and interference was warranted.

Issue (ii): Though the statutory appeal period had expired and the writ was filed belatedly, the case was treated as fit for remand rather than outright rejection. To balance the interests of both sides, the Court conditioned the fresh adjudication on the petitioner depositing 50% of the disputed tax in cash, filing an additional reply and supporting documents, and complying within the stipulated time. Consequential vacating of the bank attachment was also directed on compliance.

Conclusion: The matter was remitted to the adjudicating authority for a fresh order on merits, subject to the stipulated pre-deposit and compliance conditions.

Final Conclusion: The assessment was set aside for fresh consideration, with partial relief granted to the assessee but conditioned by a substantial pre-deposit and further procedural compliance.

Ratio Decidendi: An adjudication order under the GST regime cannot stand where it omits consideration of a prior hearing and the supporting materials, and in a delayed writ the Court may nevertheless remit the matter for fresh decision subject to equitable pre-deposit conditions.

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