Facts of the Case
The petitioner, M/s Maa Kali Cement Store Rajapur Simri,
Buxar, is a proprietary concern represented by its proprietor, Pavan Kumar
Pathak. The Assistant Commissioner of State Tax, Buxar Circle, issued an
assessment order and a consequential demand notice in Form GST DRC-07 dated
12.01.2022 for the financial period spanning April 2020 to March 2021. Through
this order, a heavy liability comprising tax, interest, and penalty totaling
$\text{Rs. } 65,89,033/-$ was imposed upon the petitioner.
Aggrieved by the assessment, the petitioner preferred a
statutory appeal before the Additional Commissioner, State Taxes (Appeals),
Patna West Division. However, this appeal was summarily rejected by the
Appellate Authority vide an order dated 29.09.2022 (issued via Memo No. 1764)
solely on the technical threshold ground of limitation, noting that the appeal
was preferred with a delay of 79 days, without touching upon or evaluating the
substantive merits of the tax dispute. Crucially, both the initial assessment
order by the Assessing Authority and the subsequent appellate rejection order
were passed ex-parte. Consequently, the tax authorities proceeded to
take coercive recovery actions, including the freezing and attachment of the
petitioner’s operational commercial bank accounts. The petitioner then filed a
Writ Petition under Article 226 before the High Court of Judicature at Patna.
Issues Involved
- Whether
the High Court, under its extraordinary writ jurisdiction under Article
226 of the Constitution of India, is precluded from interfering in a tax
dispute when an alternative statutory remedy exists, especially if the
impugned orders are ex-facie bad in law and passed in absolute
violation of the principles of natural justice?
- Whether
an ex-parte summary order passed in Form GST DRC-07 without giving
sufficient time to the taxpayer to represent their case and failing to
state discernible, speaking reasons for determining a tax liability can be
legally sustained?
- Whether
an Appellate Authority is justified in mechanically dismissing a tax
appeal purely on the grounds of a 79-day delay, completely disregarding
the underlying administrative and procedural illegalities committed during
the primary assessment proceedings?
Petitioner’s Arguments
The learned counsel appearing on behalf of the petitioner
raised several contentions against the arbitrary actions of the tax
administration:
- Violation
of Natural Justice: It was aggressively argued that the
Assessing Authority completely bypassed the principles of natural justice
by failing to issue a proper, comprehensive show-cause notice and denying
the petitioner a fair, reasonable opportunity to put forth their defense.
- Non-Adjustment
of Available Ledger Balance: The petitioner highlighted
that the authorities completely ignored and failed to adjust the Input Tax
Credit (ITC) that was already validly available in the Cash and Credit
Ledgers of the assessee while calculating the final demand.
- Mechanical
Rejection by Appellate Authority: The petitioner contended
that the Appellate Authority failed to apply its mind and dismissed the
statutory appeal on a mere 79-day delay threshold, completely shutting out
a meritorious case on hyper-technical grounds.
- Coercive
and Paralyzing Actions: The petitioner pointed out
that the ex-parte attachment and freezing of their business bank accounts
brought their active commercial operations to a standstill, causing severe
financial hardships without a lawful adjudication process.
Respondent’s Arguments
The learned counsel representing the Revenue (Union of India
and State Authorities) primarily sought to defend the statutory timeline
constraints but adopted a cooperative stance during the course of the hearing:
- Remand
Concession: Recognizing the procedural gap, the counsel
for the Revenue stated that the department would have no objection if the
entire matter was remanded back to the Assessing Authority for a fresh
determination strictly on the basis of merits.
- Waiver
of Limitation Block: The Revenue conceded that if the matter
were remanded, the issue of statutory limitation would not be allowed to
stand in the way of a fresh, merit-based adjudication.
- Interim
Protection: The Revenue accepted that no further
coercive recovery steps would be taken against the petitioner during the
pendency of the fresh assessment before the local authority.
Court Order / Findings
The Division Bench of the Patna High Court, comprising Hon’ble
Chief Justice Sanjay Karol and Hon’ble Justice Partha Sarthy, reviewed the
record and delivered a judgment reinforcing the sanctity of procedural
fairness:
- Jurisdiction
in Violations of Natural Justice: The Court firmly
established that despite the availability of statutory alternative
remedies, the High Court is not precluded from exercising its writ
jurisdiction where an order is ex-facie bad in law due to a gross
violation of the principles of natural justice.
- Fatal
Flaws in Ex-Parte Orders: The Bench observed that the
initial ex-parte assessment order failed for two primary reasons: first,
no sufficient time was granted to the petitioner to represent their case;
second, the order did not assign any clear, logical, or decipherable
reasons showing how the officer computed the heavy tax liability of over
$\text{Rs. } 65 \text{ Lakhs}$.
- Duty
to Record Reasons: The Court emphasized that even when an
administrative or tax proceeding is conducted ex-parte, the
authorities are legally bound to adjudicate the matter by considering all
attending facts and laws, and must write a speaking order assigning
reasons.
- Final
Directions and Quashing: On these short grounds, the
High Court quashed and set aside both the appellate order dated 29.09.2022
and the primary assessment order/DRC-07 dated 12.01.2022.
- Remand
Terms: The Court ordered the immediate de-freezing
and de-attachment of the petitioner's bank accounts. It directed the
petitioner to appear before the Assessing Authority on 23.12.2022, subject
to depositing an additional $10\%$ of the raised demand amount within four
weeks (in addition to the statutory $10\%$ pre-deposit already paid for
the appeal). The Assessing Authority was directed to afford an adequate
opportunity of hearing, accept essential documents, and pass a fresh,
reasoned speaking order on pure merits within a strict period of two
months. No coercive steps are to be taken against the petitioner during
this pendency.
Important Clarification
- Ex-Parte
Orders Do Not Exempt Reasoning: A key takeaway from this
judgment is that an assessing officer cannot write a cryptic, reasonless
order simply because the assessee failed to appear. The determination of
tax dues must always be backed by explicit calculations and rational
findings visible on the face of the record.
- Pre-Deposit
Adjustments: The additional deposit of $10\%$ ordered by
the High Court is strictly without prejudice to the rights of either
party, and if the final fresh assessment finds the deposit to be in
excess, the revenue is mandated to refund it within two months from the date
of the fresh order.
Section Involved
- Section
107 of the Central Goods and Services Tax (CGST) Act, 2017 / Bihar Goods
and Services Tax (BGST) Act, 2017: Appeals to Appellate
Authority.
- Section 73 / 74 of the CGST/BGST Act, 2017: Determination of tax not paid or short paid or erroneously refunded or input tax credit wrongly availed or utilized (related to the underlying assessment context of Form GST DRC-07).
Link to download the order - https://mytaxexpert.co.in/uploads/1782976978_283compressed.pdf
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