Natural justice in ITC mismatch disputes requires consideration of reconciliation material before disallowance can be sustained.

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....An adjudication order alleging ineligible input tax credit on account of a mismatch between GSTR-3B and GSTR-2A could not stand where the authority failed to consider the reconciliation statement specifically furnished by the taxpayer and did not give an effective opportunity to explain the discrepancy. The HC held that, because the dispute was factual and the reply referred to reconciliation material in Annexure-1, the authority was required to re-examine that material before concluding that no reconciliation had been produced. The order was set aside and the matter remitted for fresh consideration after giving the taxpayer an opportunity to explain the ITC mismatch.....