No Natural Justice Violation Since Reply Mentioned in GST Assessment Order, Writ Petition Not Maintainable

M.G.P.Store Vs Deputy Commissioner (GST Appeals) (State Tax) (Madras High Court)

The writ petition was filed before the Madras High Court seeking to quash an assessment order dated 28.11.2025 issued by the Deputy Commissioner (GST Appeals) under GST. The petitioner challenged the impugned order on the ground that it was passed without proper consideration of the reply submitted in response to the show cause notice.

The petitioner argued that although a reply had been filed pursuant to the show cause notice, the impugned order neither properly enumerated the reply in the reference column nor dealt with the contentions raised in it. According to the petitioner, the order merely stated that the reply was not accepted and ignored the detailed submissions made in response to the notice. The petitioner further contended that the assessing authority disregarded the reply solely because the petitioner did not appear for the personal hearing. It was argued that such non-consideration of the reply demonstrated lack of application of mind and amounted to a violation of the principles of natural justice. On this basis, the petitioner sought intervention of the High Court under Article 226 of the Constitution of India to quash the assessment order and direct the authority to grant a fresh opportunity.