Documentary proof in GST assessment led to remand for fresh verification and reconsideration of the disputed demand.

An assessment under the Tamil Nadu GST Act based on alleged mismatches, hypothetical supplies and double taxation was set aside because the dispute depended on documentary proof that the assessee said had been filed or could be produced item-wise. As the demand could not be fairly sustained without verification of those records, the matter was remanded to the original authority for fresh consideration after receipt and examination of the supporting documents. The assessee was therefore granted a de novo adjudication on the disputed tax liability before the assessing authority.

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Issues: Whether the assessment order under Section 73 of the Tamil Nadu Goods and Services Tax Act, 2017 required interference and remand for fresh consideration in view of the assessee's claim that supporting documents had been produced or could be produced item-wise.

Analysis: The assessment was founded on alleged discrepancies arising from mismatch, hypothetical supplies and double taxation, and the authority proceeded on the basis that supporting documentary proof had not been furnished. The assessee asserted that the relevant materials had already been filed and that the tax demand would not survive if the documents were duly considered. In these circumstances, instead of driving the assessee to the appellate remedy, the matter was found fit to be sent back to the original authority so that the documents could be produced item-wise, verified and the issues reconsidered afresh.

Conclusion: The assessment order was set aside and the matter was remanded to the original authority for fresh consideration after receipt and verification of the supporting documents.

Final Conclusion: The assessee obtained procedural relief by securing a de novo examination of the disputed tax demand before the assessing authority.

Ratio Decidendi: Where an assessment turns on documentary proof and the assessee is afforded an opportunity to place or identify the supporting records item-wise, the matter may be remanded to the assessing authority for fresh adjudication.

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