Mandatory hearing before GST refund rejection renders order unsustainable if no effective opportunity is granted.

A refund rejection under the GST Rules is invalid where the authority does not grant an effective opportunity of hearing before passing the order. The text states that the refund application was rejected on limitation grounds even though the applicant had requested a personal hearing by virtual mode in response to the show cause notice. Because no effective hearing was afforded, the mandatory procedural safeguard was not complied with, and the rejection order was quashed. The matter was remitted for fresh consideration in accordance with law after following the prescribed procedure.

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Issues: Whether rejection of the refund application without granting an opportunity of hearing was valid under the GST Rules.

Analysis: The refund application was rejected on limitation grounds after the petitioner had sought a personal hearing by virtual mode in response to the show cause notice. The record showed that no effective hearing was granted before passing the rejection order. The GST Rules require that a refund rejection order be passed only after affording an opportunity of hearing, and non-compliance with that mandatory procedural safeguard vitiates the order.

Conclusion: The rejection order was unsustainable and was quashed. The matter was remitted to the authority to proceed afresh in accordance with law after following the prescribed procedure.

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