Conditional remand with pre-deposit required; taxpayer given final chance to substantiate bank reconciliation before fresh assessment.

Assessment orders raising demand based on discrepancies between GSTR-3B and bank credits were remitted for fresh adjudication subject to conditions. The authority must afford a final opportunity to file a proper, substantiated reply with tabulation and bank-reconciliation supporting monthly and annual returns; on compliance and prescribed pre-deposit the matters shall be decided afresh and interim recovery measures including bank attachment will be suspended or vacated. Remand is conditional and limited to reconsideration on merits following receipt of the deposit and satisfactory substantiation.

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Issues: Whether the impugned assessment orders dated 22.07.2025 under Section 74 of the respective GST enactments are sustainable on merits or whether the matters should be remitted for fresh consideration subject to deposit and related conditions.

Analysis: The petitions challenge assessment orders raising demand mainly based on differences between amounts in Form GSTR-3B and amounts credited to the petitioner's bank account. The petitioner filed skeletal replies and later furnished bank statements by email which, according to the petitioner, were not examined before passing the impugned orders. The Court finds that the replies lack necessary tabulation and reconciliation of bank entries with monthly and annual returns and that further opportunity to submit a clear, substantiated reply is appropriate. Consistent with the Court's established approach in similar cases, a conditional remand with an order for pre-deposit and suspension of recovery measures pending fresh adjudication is an appropriate remedy where the petitioner is given a final chance to substantiate its defence.

Conclusion: The impugned assessment orders are remitted to the first respondent for fresh consideration on merits. This remand is subject to the petitioner depositing Rs. 35,00,000 from its electronic cash register within 30 days and filing a proper, substantiated reply; on compliance, the first respondent shall decide the matters afresh and the bank attachment shall be vacated. The petitioners obtain interim relief conditional on compliance.

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