Ignoring Taxpayer Reply Violates Principles of Natural Justice: HC Remands GST Case for Fresh Consideration
The Madras High Court holds that if a reply is submitted from the side of the petitioner, then ignorance of that reply by the tax authorities is considered a contravention of the principles of natural justice. Consequently, the court set aside the assessment order.
Tvl. Rock Fort Wires (petitioner) had challenged an assessment order dated December 18, 2025, passed by the tax authorities under Section 73 of the Tamil Nadu GST Act, 2017, on the grounds of the availment of excess and ineligible ITC and the late fees. However, the impugned order states that the petitioner did not furnish a reply.
The petitioner argued that it did furnish a reply on December 06, 2025, and the same is also available on the GST portal; however, the tax authorities did not consider its reply. When the court analysed the case, it found that both the preamble and the body of the impugned order failed to mention or evaluate any such replies.
The court noted that the reply was indeed submitted by the petitioner; however, the tax authorities ignored the reply. Such practice indicates an explicit violation of the principles of natural justice. Considering the same, the court quashed the impugned assessment order dated December 18, 2025, and sent the case back to the tax authorities for fresh consideration.
Additionally, the court directed the tax authorities to consider the petitioner’s earlier reply filed on December 06, 2025. It also allowed the petitioner to submit additional documents within the time limit of one week and mandated that a proper opportunity for a hearing be given. The tax authorities are directed to issue a new order after considering all materials. With these directions, the writ petition has been allowed.
Citation: Tvl.Rock Fort Wires Vs Assistant Commissioner (Madras High Court); W.P(MD)No. 7204 of 2026; 17/03/2026
