GST assessment remitted for fresh adjudication subject to a 25% disputed-tax pre-deposit.

The petitioner challenged the second respondent’s assessment order dated 30 December 2025, which confirmed proposals in a Show Cause Notice in Form DRC-01 dated 26 May 2025

The Court noted that the petitioner had replied to the notice but had not properly answered the first defect or produced documents supporting its defence to the second defect

The petitioner agreed to deposit 25% of the disputed tax in return for fresh consideration.

Whether the Court should remit the assessment for fresh consideration rather than require the petitioner to pursue an appeal

Whether remand and vacation of the bank-account attachment should be made conditional on a pre-deposit and a further reply with supporting documents

The Court exercised its writ jurisdiction under Article 226, under which it may grant appropriate relief and remit a matter for fresh decision subject to conditions.

The operative principles in this case were that the petitioner must satisfy the stated pre-deposit and filing requirements for remand and conditional lifting of the attachment; the tax authority must then decide the matter on merits and in accordance with law

Although the petitioner’s response to the show-cause notice was deficient and an appeal was available, the Court considered remand appropriate, subject to the petitioner’s undertaking to deposit 25% of the disputed tax

To enable proper reconsideration, it required the petitioner to file a further reply and supporting documents, treating the impugned assessment order as an addendum to the show-cause notice

The Court linked vacation of the bank attachment to compliance with these conditions and the absence of other tax arrears.

Within 30 days of receiving the order, the petitioner must deposit 25% of the disputed tax in cash from its Electronic Cash Register and file a reply with supporting documents.

If it complies, the authority must decide the matter on merits and in accordance with law, preferably within three months of the reply or pre-deposit; the bank attachment will stand vacated only upon the required deposit and provided there are no other tax arrears.

If the petitioner fails to comply, the respondents may recover the tax in accordance with law, after giving due notice.

The writ petition was disposed of without costs, and the connected miscellaneous petitions were closed.