Ex parte GST assessment is addressed where statutory appellate...

Ex parte GST assessment is addressed where statutory appellate limitation prevents appellate recourse. Fresh consideration is contemplated because the demand was made ex parte, provided the taxpayer files a reply to the show-cause notice, treats the impugned order as an addendum, and makes pre-deposit of the disputed tax. The respondent must then decide the matter on merits after hearing the taxpayer. Non-compliance permits proceedings in accordance with law as though the writ petition had been dismissed in limine.