GST Orders Quashed: Discount’s Tax Effect Not Considered, Matter Remanded

By | February 8, 2025

 GST Orders Quashed: Discount’s Tax Effect Not Considered, Matter Remanded

Summary in Key Points:

  • Issue: Did the original and appellate orders adequately address the issue of the tax effect of discounts, and was the assessee given a fair opportunity to present their case?

  • Facts: The petitioners challenged the original and appellate orders, alleging that they failed to consider the tax effect of discounts. They sought to remand the matter for reconsideration. The respondents argued that the petitioners should file a second appeal under Section 112.

  • Decision: The court found that the impugned orders did not adequately address the tax effect of the discount and the fact that neither the supplier nor the petitioner had sought a tax refund. This constituted a violation of natural justice. The court quashed the orders to the extent they dealt with the discount issue and remanded the appeals for reconsideration by the appellate authority, granting the petitioners an opportunity to be heard.

Important Note: This decision underscores the importance of considering all relevant aspects of a case and providing a fair hearing to the parties involved. The failure to address the tax effect of the discount and the lack of a refund claim were significant omissions that affected the fairness of the proceedings. By remanding the matter, the court ensures that the appellate authority considers these crucial aspects and provides a reasoned decision after hearing the petitioners. This ruling protects the principles of natural justice and ensures that tax disputes are resolved in a fair and comprehensive manner.

HIGH COURT OF KERALA
Deepu Prasad Kini
v.
State Tax Officer, State Goods & Service Tax
Gopinath P., J.
WP(C) NO. 28018 and 19872 OF 2023
OCTOBER  1, 2024
A. Krishnan, Adv. for the Petitioner. Smt. Jasmine M.M., Govt. Pleader for the Respondent.
JUDGMENT
[WP(C) Nos.28018/2023, 19872/2023]
1. The issues raised in these writ petitions are intrinsically connected to each other and hence they are disposed of by a common judgment. The short issue is regarding the treatment of the amount of discount received by the petitioners from their suppliers.
2. Learned counsel appearing for the petitioner submits that there is no tax effect on account of the discount granted and that the matter has not been considered properly by the Appellate Authority or by the Assessing Authority and he will be satisfied if the matter is remanded to the appellate Authority for fresh consideration.
3. Though the learned Government Pleader attempted to establish that the remedy of the petitioner against the appellate order is to file a second appeal under Section 112 of the CGST/SGST Acts, considering the limited nature of relief now sought for by the petitioner, I am of the view that the matter can be remanded to the Appellate Authority for fresh consideration as it does not appear from the original order or from the appellate order (in both cases) that this issue has been considered in a proper perspective. The fact that the grant of discount has no tax effect has not been considered. The fact that the supplier/or the petitioner have not sought for any refund of tax has also not been considered.
Accordingly, Ext.P2 order in W.P.(C.) No. 19872 of 2023 and Ext.P2 order in WP(C) Nos.28018 of 2023 are quashed and the respective appeals filed by the petitioners against Ext.P1 order of assessment (in both the cases) are restored to the file of the First Appellate Authority, who shall pass fresh orders, after affording an opportunity of hearing to the petitioners. It is made clear that orders (Ext.P2 in both cases) are set aside only to the extent that they consider the issue related to discount received by the petitioners and on no other issues.
The writ petitions are disposed of as above.
Category: GST

About CA Satbir Singh

Chartered Accountant having 12+ years of Experience in Taxation , Finance and GST related matters and can be reached at Email : Taxheal@gmail.com