Assessment under GST requiring fresh adjudication on remand; petitioner must produce e-way bills and transport documents within thirty days.

Assessment under GST noted transcriptional error in the annual return and alleged failure to produce e-way bills; the respondent must undertake de novo adjudication after the petitioner furnishes all e-way bills and supporting transport documents, and may not rely on sample documents. Petitioner must submit detailed reply with specified documents within thirty days; bank account attachment is conditionally maintained pending compliance, and the authority may proceed to recover tax as if the writs were dismissed if petitioner fails to comply. The matter is remitted for fresh adjudication with directions to consider the filings and evidence afresh and pass appropriate orders.

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Issues: Whether the impugned GST assessment orders require fresh adjudication because the petitioners contentions about alleged transcription errors in GSTR-09 and supporting documents were not dealt with by the assessing authority.

Analysis: The assessment orders for the tax periods (except 20222023) do not refer to or deal with the petitioners replies and additional submissions which assert that Input Tax Credit was misstated due to transcription between 'inputs' and 'input services' in Form GSTR-09. The petitioners filings and the annual returns prima facie indicate a possible mistake that warrants detailed consideration. Given the substantial disputed amounts and incomplete adjudication of the petitioners explanations and documents, the matter requires reconsideration on merits with opportunity to furnish all invoices, GSTR-2A, GSTR-2B, GSTR-3B and complete e-way bills and transport documents. The Court conditions de novo adjudication on the petitioner paying specified costs and furnishing proof of compliance, and provides consequential directions regarding lifting of attachment upon compliance.

Conclusion: The assessment orders are set aside and the matters are remitted to the assessing authority for de novo adjudication after the petitioner complies with stipulated conditions including payment of costs and submission of full documentary proof; on compliance the assessing authority shall decide the cases on merits and the bank account attachment shall be lifted.

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