Natural justice in GST adjudication requires consideration of the reply and a meaningful opportunity of hearing before passing orders.

GST adjudication orders cannot be sustained where the taxpayer's reply to the show-cause notice and request for personal hearing are not properly considered. The adjudicating authority proceeded on the incorrect assumption that no reply had been filed and no hearing sought, and the rectification order did not cure the defect because it still showed no meaningful consideration of the explanation or independent application of mind. Such an order breaches natural justice, as a reply to a show-cause notice is not an empty formality. The impugned orders were quashed and the matter remanded for fresh adjudication after granting a reasonable opportunity of hearing.

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Issues: Whether the GST adjudication orders could be sustained when the reply to the show-cause notice and the request for personal hearing were not duly considered and no effective opportunity of hearing was afforded to the petitioner.

Analysis: The reply to the show-cause notice showed that the petitioner had opted for personal hearing. The adjudication order proceeded on an erroneous premise that no reply had been filed and no hearing had been sought. The rectification order also did not cure the defect, as it still disclosed no meaningful opportunity of hearing and no consideration of the explanation offered in the reply. An adjudicatory order under the GST law must reflect consideration of the taxpayer's response and must be supported by reasons showing independent application of mind; a reply to show-cause notice is not an empty formality.

Conclusion: The impugned orders were unsustainable for breach of natural justice and want of consideration of the reply. They were quashed and the matter was remanded for fresh adjudication after granting reasonable opportunity of hearing.

Final Conclusion: The dispute was sent back to the adjudicating authority for decision on merits in accordance with law after hearing the petitioner.

Ratio Decidendi: An adjudication order under the GST regime cannot be sustained if it ignores the taxpayer's reply and is passed without affording or reflecting a meaningful opportunity of hearing.

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