Opportunity of hearing requires fresh adjudication when post hearing submissions and hearing requests were not considered, resulting in quashing.

Section 75(4) of the Central Goods and Services Tax Act requires an opportunity of hearing before passing an adverse order; the authority failed to consider post hearing online submissions, an email and an additional reply and did not grant the reiterated request for a personal hearing before issuing the impugned order dated 20.08.2025. For breach of this statutory entitlement and the principles of natural justice the impugned order and the subsequent demand notice were quashed and the matter remanded for fresh adjudication after affording a personal hearing; no comment made on merits.

---

---

Issues: Whether the impugned order dated 20.08.2025 was passed in violation of Section 75(4) of the Central Goods and Services Tax Act, 2017 and the principles of natural justice by failing to consider the petitioner's additional reply and requests for a personal hearing.

Analysis: Section 75(4) of the Central Goods and Services Tax Act, 2017 requires that the adjudicating authority afford opportunity of hearing before passing an order that may be adverse to the taxpayer; this statutory entitlement engages the principles of natural justice. The record shows that a personal hearing was held on 11.07.2025, subsequent online submissions and an email dated 21.07.2025 and an additional reply dated 14.08.2025 were submitted and a request for personal hearing was reiterated, but those submissions were not considered by the authority when passing the impugned order dated 20.08.2025. The court examined the sequence of filings and communications and found that the additional material was not taken into account prior to the order; consequently the statutory requirement and the petitioner's opportunity to be heard were not complied with.

Conclusion: The impugned order dated 20.08.2025 is quashed and set aside for breach of Section 75(4) of the Central Goods and Services Tax Act, 2017 and the principles of natural justice. The demand notice in Form DRC-07 dated 04.09.2025 is quashed and set aside. The matter is remanded to the competent authority to pass a fresh order after following the statutory provisions and granting a personal hearing. The quashing is on technical/procedural grounds and no expression is made on the merits of the case.

---