Conditional remand in GST assessments with partial pre-deposit, while taxability of seigniorage fees under reverse charge remained undecided.

GST assessment orders under Section 74 were interfered with only to the extent of a conditional remand: the taxability dispute, including reverse charge treatment of seigniorage fees, was not decided on merits. The petitioners were required to make a partial cash pre-deposit, file replies to the show cause notices, and produce supporting documents for fresh adjudication. On compliance, the bank attachment was directed to be vacated. The matters were therefore sent back for reconsideration subject to procedural compliance and deposit conditions, with interim relief tied to fulfilment of those directions.

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Issues: Whether the impugned GST assessment orders could be interfered with and the matters remitted for fresh consideration, and whether conditional pre-deposit could be directed in respect of the disputed demand including the issue of tax on seigniorage fees under reverse charge mechanism.

Analysis: The writ petitions challenged assessment orders passed under Section 74 of the GST enactments for alleged short payment of tax and non-payment of tax on seigniorage fees under reverse charge mechanism. The order did not finally decide the taxability dispute on merits. Instead, it adopted a conditional remand course, requiring partial cash pre-deposit within a stipulated time, filing of replies to the show cause notices, and production of supporting documents. It also directed that the bank attachment would stand vacated on compliance.

Outcome: The assessment matters were sent back to the respondent for fresh adjudication subject to pre-deposit and compliance with procedural directions, and interim bank attachment relief was granted conditionally.

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