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Ex parte GST assessment permits fresh adjudication subject to reply and disputed-tax pre-deposit despite expired appellate limitation.

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....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.....