The petitioner challenged an order-in-original on the ground that although a reply to the show cause notice was duly filed on the GST portal, the adjudicating authority erroneously recorded that no reply was submitted. The factual background was supported by portal records showing the status as “Reply furnished, pending for order by tax officer.”
The Court held that the finding of the authority was contrary to record and resulted in denial of opportunity of hearing. Non-consideration of the reply amounted to gross violation of principles of natural justice. The impugned order was set aside with directions to consider the reply and proceed afresh.