Meaningful opportunity to file supplementary GST reply through the portal required; refund rejection set aside and remanded.

Where GST proceedings are conducted entirely through an online portal, the noticee must have a workable facility to seek and file a supplementary reply before adjudication. Denial of a meaningful opportunity to place the full defence on record, including inability to use the portal for an additional reply, can amount to procedural prejudice not cured by relegating the party to appeal. The HC set aside the order rejecting the refund claim and remitted the matter for fresh adjudication after granting one opportunity to file an additional or supplementary reply.

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Issues: Whether the petitioner was denied a meaningful opportunity to file an additional or supplementary reply through the GST portal, and whether the assessment order rejecting refund required interference and remand.

Analysis: The proceedings under the GST framework were conducted through online mode for issuance of notice, filing of reply, and communication of the order. In that setting, a portal mechanism for supplementary replies was necessary, or at least a controlled request-based facility enabling the noticee to seek permission to file a further reply before the next date of hearing. The petitioner's inability to file the additional reply online, coupled with the attempt reflected in the grievance process, showed that the reply before adjudication was not complete from the petitioner's standpoint. Relegating the petitioner to an appeal would not cure the prejudice caused by the absence of an effective opportunity to place the full defence before the adjudicating authority.

Conclusion: The order rejecting the refund application was set aside and the matter was remitted for fresh adjudication after granting one opportunity to file an additional or supplementary reply.

Final Conclusion: The petitioner succeeded in obtaining restoration of the adjudicatory process so that the refund claim could be reconsidered after a fuller reply on merits.

Ratio Decidendi: Where proceedings are conducted primarily through an online statutory portal, the noticee must be afforded a workable procedural facility to seek and file a supplementary reply before adjudication, and denial of such opportunity can justify setting aside the order and remitting the matter.

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