Facts of the Case
The petitioner, Tvl. SRK Tex (represented by its
Proprietrix Sasirekha), is a registered dealer engaged in business operations
under the GST regime. The respondent, The State Tax Officer (FAC), Karur - 3
Assessment Circle, initiated assessment proceedings for the Assessment Year
(AY) 2017-18.
During the verification process, the respondent department
identified an alleged discrepancy involving the excess availment of Input Tax
Credit (ITC) amounting to ₹9,08,516/- (IGST). This discrepancy was calculated
based on a mismatch discovered between the petitioner’s monthly returns filed
in Form GSTR-3B and the auto-populated purchase details in Form GSTR-2A for the
financial year 2017-18.
The respondent uploaded the show-cause notices and subsequent
assessment communications solely onto the official GST portal. Because these
notices were never effectively communicated to the petitioner through physical
mode or direct alert, and because the petitioner had entrusted the compliance
management to a part-time accountant who completely failed to monitor the
portal or inform the petitioner, the entire proceeding went unnoticed.
Consequently, the petitioner could not file any written objections or present
supporting evidence, leading the respondent to pass an ex-parte assessment
order dated 30.12.2023. The order treated the entire mismatched ITC amount
as ineligible, proposing its recovery along with applicable interest and
penalties under Section 73. Aggrieved by this, the petitioner moved a Writ of
Certiorari before the High Court.
Issues Involved
- Whether
the ex-parte assessment order dated 30.12.2023 passed under Section 73 of
the CGST/TNGST Act was legally sustainable since the notices were hosted
only on the GST portal without effective communication, thereby violating
the principles of natural justice.
- Whether
the petitioner should be granted an equitable opportunity to present
evidence establishing that the alleged excess ITC mismatch had already
been voluntarily reversed with interest in subsequent tax periods.
Petitioner’s Arguments
- Violation
of Natural Justice: The petitioner argued that the entire
assessment proceedings were hosted exclusively on the GST portal and were
never effectively served or communicated directly to the dealer. As a
result, the petitioner was entirely unaware of the ongoing case and was
deprived of a fair hearing.
- Reason
for Non-Appearance: The petitioner submitted that being
unfamiliar with the intricate digital workflows of the GST portal, the
firm had completely relied on a part-time accountant. The accountant
failed to check the portal dashboard and did not alert the management
regarding the notices.
- Revenue
Neutrality & Prior Reversal: On the merits of the tax
liability, the petitioner contended that the excess ITC claim was an
inadvertent clerical error typical of the initial transition phase of GST
implementation in 2017-18. Crucially, the petitioner had already
voluntarily reversed the disputed ITC during the months of May 2018 and
June 2018 (Financial Year 2018-19) along with the payment of applicable
interest.
- No
Loss to the Exchequer: Because the reversal entries occurred
in the subsequent financial year, they did not reflect in the assessment
records specifically pulled for FY 2017-18. The petitioner claimed that
the issue is entirely revenue-neutral, causing zero loss to the government,
making the impugned demand an double-taxation error based on the
respondent’s incomplete assumptions.
Respondent’s Arguments
The respondent, represented by the Government Advocate,
defended the validity of the assessment order. The revenue argued that the
department had scrupulously followed the standard statutory operating
procedures by uploading the notices on the official GST portal. The respondent
stressed that it is the active legal responsibility of every registered
taxpayer to routinely monitor their GST portal dashboard for updates, notices,
or communications. Since the petitioner failed to utilize multiple opportunities
extended during the assessment cycle, the department was fully justified in
finalizing the assessment ex-parte based on the available data showing a stark
mismatch between GSTR-3B and GSTR-2A.
Court Order / Findings
The Madurai Bench of the Madras High Court, presided by
Hon'ble Justice D. Bharatha Chakravarthy, carefully evaluated the
discrepancies, the subsequent explanations, and the practical reasons cited for
the lack of portal monitoring.
The Court observed that in the interest of justice and
fairness, the taxpayer deserved a proper opportunity to lay out their documents
and demonstrate the voluntary reversal entries before the assessing officer.
Highlighting that the court regularly extends such relief on equitable grounds
under reasonable terms, it allowed the Writ Petition with the following
conditions:
- Conditional
Pre-deposit: The petitioner must deposit 25% of the
disputed tax amount with the respondent department within four weeks
of receiving the web copy of the order, without waiting for the certified
hard copy.
- Setting
Aside and Remand: Upon successful completion of the 25%
deposit, the impugned ex-parte assessment order dated 30.12.2023 will
stand set aside automatically, and the entire matter will stand remanded
back to the assessing officer for a fresh look.
- Fresh
Opportunity: The petitioner is directed to appear before
the respondent assessing officer without fail, submit a comprehensive
reply, and file all supporting documents. The respondent will then
evaluate the matter afresh and pass a lawful order.
- Lifting
of Bank Attachment: Consequent to the setting aside of the
assessment order, any active bank account attachments executed by the
department for recovery purposes shall stand raised/lifted immediately.
- No
Costs: The petition was disposed of without any
order as to costs, and all connected miscellaneous petitions were closed.
Important Clarification
This ruling provides an essential procedural clarification for
businesses relying on external or part-time accounting professionals: The
High Court reaffirms that while portal-only communication can technically
result in harsh ex-parte orders if neglected, the judiciary will lean towards
granting an opportunity to defend on merits if the taxpayer can present a bona
fide case of revenue neutrality (such as showing the tax was already reversed
with interest in later returns). However, this judicial relief is conditional,
requiring the taxpayer to deposit a portion (25% in this case) of the disputed
liability to test their bona fides.
Section Involved
- Section
73 of the Central Goods and Services Tax (CGST) Act, 2017 / Tamil
Nadu Goods and Services Tax (TNGST) Act, 2017.
- Section
73(10) of the TNGST Act, 2017 (referenced regarding
limitation periods in the prayer).
- Article 226 of the Constitution of India (under which the Writ Petition for Certiorari was filed).
Link to download the order - https://mytaxexpert.co.in/uploads/1783061650_334compressed.pdf
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