HC remanded matter as adjudicating authority failed to apply its mind to contentions raised in reply to SCN {GlobeOp Financial Services (India) (P.) Ltd. vs. Deputy Commissioner of State Tax, Mumbai [2025] 176 taxmann.com 213}
Issues:
- Whether the adjudicating authority complied with principles of natural justice?
- Whether an order simply reiterating SCN content without addressing replies is valid under GST law?
Facts:
- Petitioner (GlobeOp) was served a GST demand order under Section 73 of the CGST/MGST Act for FY 2020–21.
- Petitioner argued that the order was a verbatim copy of the show cause notice and failed to consider the detailed replies it submitted.
- No independent reasoning or application of mind was reflected in the order.
Held:
- Court found that the order lacked application of mind and was mechanically passed by copying SCN allegations.
- Such an order violates principles of natural justice.
- It was set aside, and the matter was remanded for fresh adjudication after proper consideration of the assessee’s submissions.
