Facts of the Case
The petitioner, Tvl. K.R.K. Timbers, engaged in the
business of timber and exempt firewood, challenged an ex parte assessment order
passed under Section 73 of the TNGST Act for Assessment Year 2020-21. The
department alleged excess availment of Input Tax Credit (ITC) amounting to
₹13,01,251 due to mismatch between GSTR-3B and GSTR-2A. It was further alleged
that the petitioner had wrongly availed common ITC attributable to exempt
firewood turnover without reversing the same under Section 17 of the GST Act.
The assessment proceedings were conducted through the GST
portal. As the petitioner failed to respond to notices, an ex parte assessment
order was passed raising tax, interest, and penalty. Aggrieved by the order,
the petitioner approached the Madras High Court seeking quashing of the assessment
and remand for fresh adjudication.
Issues Involved
- Whether
an ex parte assessment passed under Section 73 without effective
participation of the assessee deserves to be set aside.
- Whether
alleged ITC mismatch between GSTR-3B and GSTR-2A requires verification of
supporting documents before disallowing ITC.
- Whether
separate maintenance of accounts for taxable and exempt supplies requires
reconsideration before invoking Section 17 for ITC reversal.
- Whether
principles of natural justice warrant remand where sufficient explanation
is offered for non-participation in assessment proceedings.
Petitioner's Arguments
The petitioner submitted that:
- It
is engaged in trading taxable timber and exempt firewood (HSN 4401).
- Separate
accounts were maintained for taxable and exempt supplies.
- No
ITC was claimed on purchases relating to exempt firewood transactions.
- The
mismatch between GSTR-3B and GSTR-2A arose because certain suppliers
mistakenly reported transactions as B2C instead of B2B, resulting in
eligible ITC not appearing in GSTR-2A.
- Valid
tax invoices, purchase registers, books of account, reconciliation
statements, and supplier confirmations were available to establish the
genuineness of the ITC claim.
- The
department failed to verify these records before concluding that the ITC
was ineligible.
- The
petitioner could not participate in the proceedings because GST compliance
had been entrusted to a part-time accountant, who failed to monitor the
GST portal and did not inform the petitioner about the notices or hearing
dates, resulting in an ex parte order without an effective opportunity of
hearing.
Respondent's Arguments
The department contended that:
- The
petitioner had availed excess ITC of ₹13,01,251 based on mismatch between
GSTR-3B and GSTR-2A.
- The
petitioner failed to reverse common ITC attributable to exempt firewood
turnover under Section 17 of the GST Act.
- Despite
opportunities provided through the GST portal, the petitioner failed to
participate in the assessment proceedings.
- Consequently,
the assessment under Section 73, along with demand of tax, interest, and
penalty, was validly passed.
Court Order / Findings
The Madras High Court observed that:
- The
petitioner had furnished a plausible explanation both regarding the
alleged discrepancies and the reasons for non-participation in the
assessment proceedings.
- Considering
the nature of the dispute and the explanation offered, one more
opportunity should be granted to the assessee to submit documents and
explanations before the assessing authority.
- Since
the commodity involved, namely firewood, is an exempt commodity under GST,
the Court deemed it appropriate to grant relief without imposing any
pre-deposit or other conditions.
- The
impugned assessment order dated 07.02.2025 was set aside.
- The
matter was remanded to the assessing authority for fresh adjudication
after considering the petitioner's reply and supporting documents.
- Any
bank attachment made pursuant to the impugned assessment order was
directed to be lifted.
- The
assessing authority was directed to pass fresh orders strictly in
accordance with law after granting adequate opportunity to the petitioner.
Important Clarification
This judgment reiterates that:
- Mere
mismatch between GSTR-2A and GSTR-3B cannot automatically result in denial
of ITC without verification of supporting records.
- Separate
maintenance of accounts for taxable and exempt supplies must be properly
examined before invoking Section 17 for reversal of ITC.
- Ex
parte GST assessments may be interfered with where the assessee
establishes sufficient cause for non-appearance.
- Courts
continue to uphold the principles of natural justice by granting an
effective opportunity of hearing, particularly where genuine documentary
evidence is available.
- Attachment
of bank accounts based solely on an assessment order cannot survive once
such assessment is set aside.
Sections Involved
- Section
73, Tamil Nadu Goods and Services Tax Act, 2017
- Section
17, Central Goods and Services Tax Act, 2017
- Article 226 of the Constitution of India
Link to download the order-https://mytaxexpert.co.in/uploads/1783925582_402compressed.pdf
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