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Assessee attempted Suicide as he suffered huge loss in business due to Corona Covid on 27-Dec-2020.
Was admitted to Hospital and was in life-death situation.
Department issued Show Cause Notice for non-filing of his GST Returns for continuous 6 months within 7 days and
appear before the Authority on 4-Jan-2021.
Surprisingly when GST Registration Cancellation Order was passed it was mentioned in the Order that Petitioner's reply filed on 15-Jan-2021 is considered whereas neither he was in the condition to file reply nor he filed any reply.
When Assessee he came out of mental stress he approached High Court against this cancellation.
High Court held
✅ He should be given an opportunity of hearing.
✅But in order to avail of such opportunity, the petitioner shall first make payment of up to date GST
with statutory interest and penalty within three weeks from the date.
Title: DYM Auto World vs Assistant Commissioner Of Cgst And Central Excise
Court: Calcutta High Court
Citation: W.P.A. No. 36 of 2023
Dated: 30-Jan-2023
Department should be careful while passing an Order.
When Assessee has not filed any reply then mentioning that his reply is considered in itself proves that Order was Cut-Copy-Paste.
Judgement of Gujarat High Court in case of Aggarwal Dyeing and Printing Works vs State of Gujarat (SCA No.18860 of 2021) dated 24-Feb-2022 is also
same. It was held in that case, "it is settled legal position of law that reasons are heart and soul of the order and non communication of same itself amounts to denial of reasonable opportunity of hearing, resulting in miscarriage of justice." (Para 11)