Natural justice and statutory appeal under GST bar writ relief where no reply or hearing request was made.

Writ relief was held not maintainable against a GST demand order where the assessee had not replied to the show-cause notice or sought a personal hearing, and the proceedings were treated as falling under Section 73 of the GST Act. The Court found no breach of Section 75(4) or natural justice on those facts, because a hearing is contemplated on request. It further held that the dispute could be pursued in the statutory appeal under Section 107, and writ jurisdiction could not be used to bypass that remedy after limitation had run. The petitions were dismissed with liberty to seek appellate relief and condonation of delay as permitted by law.

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Issues: Whether the writ petitions were maintainable against the GST demand order in view of the statutory appellate remedy, and whether there was any violation of natural justice for want of personal hearing under the GST framework.

Analysis: The notices and final order were treated as proceedings under Section 73 of the GST Act. The petitioners did not file replies to the show-cause notices and did not request a personal hearing, while the statute contemplates hearing upon appropriate request. The Court held that, in these circumstances, there was no violation of Section 75(4) of the GST Act or of the principles of natural justice. The Court also held that the impugned order raised issues that were available to be challenged in appeal under Section 107 of the GST Act, and the writ jurisdiction could not be invoked after the appellate limitation had expired. Rule 142 of the CGST Rules was not accepted as a basis to bypass the statutory remedy.

Conclusion: The writ petitions were not entertained and were dismissed, with liberty to pursue the statutory appellate remedy and seek condonation of delay as available in law.

Ratio Decidendi: Where a taxable person does not respond to the show-cause notice or seek a hearing, and an efficacious statutory appeal is available, writ relief is ordinarily not maintainable absent a demonstrable breach of natural justice.

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