Reasoned Speaking Orders required: non-speaking tax orders quashed; fresh show cause notice, personal hearing and detailed orders mandated.

Impugned tax orders were quashed for failing to constitute reasoned, speaking decisions and for denying meaningful opportunity to be heard: the orders contained only bald assertions of non-production of documents, mechanically confirmed liability and did not address individual contentions or explain rejection, while the rectification simply reiterated the earlier non-speaking order. The remedy directed is issuance of a fresh show cause notice, grant of personal hearing and passage of detailed speaking orders; coercive recovery is stayed pending fresh adjudication.

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Issues: (i) Whether the impugned Order-in-Original dated 19 April 2024 and the rectification order dated 9/10 July 2024 are non-speaking, mechanically passed orders in violation of the principles of natural justice and therefore liable to be quashed.

Analysis: The impugned orders were examined on the limited question of whether they contain reasoned findings addressing the submissions and documents placed on record. The orders record only bald statements that the office has gone through the taxpayer's submission and that relevant documents were not produced, confirm liability and direct recovery under the relevant provisions of the GST laws, without dealing with individual contentions or explaining the basis for rejecting the submissions. The rectification order merely upheld the earlier order without independent reasoning. The applicable legal framework requires reasoned, speaking orders and opportunity for hearing before raising tax demands. Mechanical confirmation of liability without specific, intelligible findings causes prejudice and hardship and impairs the right to be heard.

Conclusion: The impugned Order-in-Original dated 19 April 2024 and the rectification order dated 9/10 July 2024 are quashed for being non-speaking and in violation of principles of natural justice; the respondents are directed to issue a fresh show cause notice, grant personal hearing and pass detailed speaking orders; coercive action is stayed until fresh orders are passed.

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