Pre-deposit requirement in GST appeals where input tax credit mismatch leads to remand, conditional relief on deposit.

The text addresses pre-deposit requirements in a GST appeal arising from excess input tax credit claimed due to mismatch between GSTR-2A and GSTR-2B, and the remittal for fresh adjudication. The adjudicatory authority is directed to reconsider the matter on merits, conditional on the petitioner depositing an additional 40% of the disputed tax (over the earlier 10%) within 30 days and filing a detailed reply to the show cause notice treating the impugned order as an addendum; bank attachment is to be lifted upon compliance, and failure permits recovery proceedings as if the petition were dismissed.

---

---

Issues: Whether the impugned assessment order dated 30.08.2024 and the appeal rejection dated 10.12.2025 should be set aside and the matter remitted to the assessing authority for fresh adjudication subject to conditions.

Analysis: The petition challenges the assessment order and the appellate rejection on limitation. The petitioner had submitted a reply to the Show Cause Notice and later relied on Notification No.18/2022-Central Tax. The petitioner's explanation was treated as inadequate and inconsistencies in the petitioner's stand were noted. The proceedings were examined in light of the material on record and the need for a fresh consideration on merits while protecting revenue by ensuring a pre-deposit. The remittance directs the authority to treat the impugned order as an addendum to the show cause notice, permit filing of an additional detailed reply with documents, and decide the matter on merits after an additional pre-deposit and notice to the petitioner.

Conclusion: The assessment order dated 30.08.2024 and the appellate rejection dated 10.12.2025 are set aside to the extent that the matter is remitted to the first respondent for fresh adjudication on merits subject to the petitioner depositing an additional 40% of the disputed tax (over and above the earlier 10% pre-deposit) within 30 days and filing an additional detailed reply; on compliance the authority shall decide the matter expeditiously and the bank attachment shall be lifted.

---