Before stipulated time lapses , Assessee should be given proper opportunity of being heard under section 129 of CGST Act

Case Title

NTC Industries Ltd Vs State Tax Officer , Karagpur Zone & Ors.

Court

Calcutta High Court

Honorable Judges

Justice J. T.S Sivagnanam and Justice Hiranmay Bhattacharya

Citation

2022 (6) GSTPanacea 123 HC Calcutta
MAT 557 of 2022

Judgement Date

07-June-2022

Council for Petitioner

Anil Kumar Dugar

Rajarshi Chatergee

Gobinda Dey

Gobinda Jethalia

Council for UOI

 

Council for State

A. Ray

T. M. Siddiqui

D. Ghosh

The Calcutta High Court bench of Justice T. S Sivagnanam and Justice Hiranmay Bhattacharya has held that The Assessee should be given alternative remedy to present his facts before rejecting any appeal to authority before stipulated time

FACTS OF THE CASE

The appellant (Taxpayer) has been furnished order dated 31st Mar 2022 under section 129(3) of CGST Act, 2017 wherein the single judge bench appellate authority has dismissed the explanation of appellant.

As per respondent counsel the assesee has been served and SCN dated 27th Mar 2022, while assessee submitted it to receive on 29th Mar 2022. The time limit to reply against the show cause notice was 7 days which is as per assessee is 2nd April 2022.

The respondent before the stipulated time frame passed the order dated 31st Mar 2022 stating that reply submitted by assessee was not acceptable and dismissed. While there was no objection has been filed by the petitioner(assessee) against the order but only a letter which he’s been communicated on the first instance when he went for giving explanation of movement of goods and transaction.

COURT HELD

Considering the facts as recorded, this court held and accept the views of petitioner and set aside the order passed on 31st mar 2022, in view of against the principal of natural justice. And said the assessee has been given 10 days time to submit his representation to concerned authority from the date of this order.

All the proceeding in this behalf has been set aside forthwith till the conclusion.

ANALYSIS OF THE JUDGEMENT

No order passed by the authority shall be prejudice against the principal of natural justice and cannot be set final before the expiry of stipulated time limit mentioned in the show cause notice. Further proper and fair opportunity of being heard and explain must be given under the provision of this Act.

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NTC Industries Ltd

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Calcutta High Court