Export turnover mismatches require documentary substantiation and a meaningful opportunity before ex parte GST adjudication is finally sustained.

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....Discrepancies between export turnover reported in Forms GSTR-3B and GSTR-1 require a registered taxable person to receive an opportunity to produce documents establishing the nature of the transactions and substantiating export turnover. Where non-participation in GST adjudication is explained and applicable Board Circulars contemplate such documentary verification, an ex parte determination may require fresh consideration. The appellate rejection based on inability to condone delay beyond 120 days and the adjudication order were quashed, with the proceedings restored for reconsideration after production of supporting documents and issuance of a reasoned order.....