Ex parte GST adjudication may warrant fresh consideration where...

Ex parte GST adjudication may warrant fresh consideration where a taxpayer did not answer a show-cause notice or contest proceedings because of asserted health-related inability. A justice-oriented approach supports reopening from the reply stage, permitting submission of supporting material and a reasonable hearing. A limitation-based dismissal of the statutory appeal did not involve examination on merits; the procedural focus is restoration of an effective opportunity to reply and be heard.