Facts of the Case
The petitioner challenged the assessment order
dated 06.09.2022, as rectified on 13.09.2022, passed under
Section 74 of the CGST/UPGST Act, 2017.
The petitioner submitted that after receiving the
Show Cause Notice dated 17.12.2021, it filed a detailed reply on 23.12.2021
in Form GST DRC-06 and specifically opted for a personal hearing by
selecting the relevant option in the prescribed form.
Despite the request, the GST authority neither
communicated the date, time nor venue of the personal hearing and proceeded to
pass the assessment order.
The Revenue defended the action by contending that
the notice dated 17.12.2021 was merely a reminder notice because the petitioner
had not replied to an earlier notice dated 27.08.2020.
Issues Involved
- Whether granting a personal hearing under Section 75(4) of the
CGST/UPGST Act is mandatory before passing an adverse assessment order.
- Whether an assessment order passed without affording the requested
personal hearing violates the principles of natural justice.
- Whether the existence of an appellate remedy under Section 107 bars
the High Court from entertaining a writ petition where there is a
violation of natural justice.
Petitioner’s Arguments
- The petitioner argued that while submitting the reply in Form
GST DRC-06, it had expressly requested a personal hearing.
- No notice specifying the date, time and venue of the hearing
was ever communicated before passing the assessment order.
- The petitioner relied upon the Division Bench judgment in Bharat
Mint and Allied Chemicals vs Commissioner Commercial Tax & Others,
wherein it was held that Section 75(4) makes personal hearing mandatory
whenever requested or whenever an adverse order is contemplated.
- It was submitted that the assessment order was liable to be quashed
for violation of statutory provisions and principles of natural justice.
Respondent’s Arguments
- The Revenue contended that the notice dated 17.12.2021 was
only a reminder notice.
- It was argued that since the petitioner had failed to submit any
reply to the earlier notice dated 27.08.2020, no further
opportunity of personal hearing was required.
- The respondents therefore justified the assessment order passed
under Section 74 of the Act.
Court Order / Findings
The Allahabad High Court allowed the writ petition
and held that Section 75(4) of the CGST/UPGST Act makes the grant of personal
hearing mandatory in two situations:
- Where the taxable person requests a personal hearing; or
- Where the authority proposes to pass an adverse order.
The Court observed that:
- The Show Cause Notice itself mentioned that the petitioner could
appear for personal hearing, yet the columns relating to date, time and
venue were marked as "NA".
- The petitioner had specifically requested personal hearing in Form
GST DRC-06, but no hearing was ever granted.
- Denial of personal hearing amounted to violation of Section 75(4)
as well as the principles of natural justice.
- Although an appellate remedy under Section 107 was available, the
writ petition was maintainable because violation of natural justice
constitutes a recognised exception to the rule of alternative remedy.
Accordingly, the assessment order dated 06.09.2022,
as rectified on 13.09.2022, was set aside, and the matter was
remanded to the proper officer for passing a fresh order after granting a
proper opportunity of personal hearing.
Important Clarification
- Personal hearing under Section 75(4) is a mandatory
statutory requirement whenever specifically requested by the taxpayer
or whenever an adverse order is proposed.
- Merely issuing a Show Cause Notice without specifying the date,
time and venue of hearing does not satisfy the statutory requirement.
- The availability of an appeal under Section 107 does not prevent
the High Court from exercising writ jurisdiction where there is a clear
violation of natural justice.
- Assessment orders passed without complying with Section 75(4) are
liable to be quashed irrespective of the merits of the tax demand.
- GST authorities must strictly comply with procedural safeguards
before finalising proceedings under Section 74.
Key Takeaway
The Allahabad High Court reaffirmed that Section
75(4) of the CGST/UPGST Act is mandatory, and no assessment under Section
74 can be sustained where the taxpayer is denied the requested personal
hearing. The judgment further reiterates that breach of natural justice
constitutes a valid ground for invoking writ jurisdiction notwithstanding the
statutory appellate remedy.
Sections Involved
- Section 74 of the Central Goods and
Services Tax Act, 2017 / Uttar Pradesh Goods and Services Tax Act, 2017 –
Determination of tax involving fraud, wilful misstatement or suppression
of facts.
- Section 75(4) of the CGST/UPGST Act, 2017
– Mandatory opportunity of personal hearing.
- Section 107 of the CGST/UPGST Act, 2017
– Appeal to Appellate Authority.
- Article 226 of the Constitution of
India – Writ Jurisdiction.
- Principle of Natural Justice (Audi Alteram Partem).
Link to download the order - https://mytaxexpert.co.in/uploads/1782968966_228compressed.pdf
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