Personal hearing requirements in GST adjudication were satisfied by prior opportunities and written submissions; appellate limitation received writ-pendency exclusion.

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....A personal hearing is required before adverse GST adjudication where the assessing authority contemplates an adverse decision after considering the taxpayer's representation. The notes state that three hearing opportunities, followed by written final submissions from the authorised representative, satisfied that requirement; no further hearing was necessary merely because the order was issued later. The challenge on that ground remained closed. Statutory appellate recourse was permitted, with the writ-pendency period excluded for computing limitation and the condonable period, while other issues remained open. Refund of tax recovered was declined because the writ was filed after the statutory appeal period had expired.....