Appeal to be Considered on Merits if Assessee Initialy failed to pre-deposit 20% amount online But Later deposited the Amount

By | February 8, 2025

Appeal to be Considered on Merits if Assessee Initialy failed to pre-deposit 20% amount online But Later deposited the Amount

Summary in Key Points:

  • Issue: Was the dismissal of the petitioner’s appeal justified due to an inadvertent error in not indicating the pre-deposit amount online, even though the pre-deposit was subsequently made?

  • Facts: The petitioner filed an appeal but inadvertently failed to indicate the pre-deposit amount online. They later rectified the error by making the mandatory 10% pre-deposit from their electronic cash ledger. However, the appellate authority dismissed the appeal due to the initial error.

  • Decision: The court held that dismissing the appeal for an inadvertent error, even after it was corrected, was excessively disproportionate. The appellate authority should have adopted a more lenient approach and considered the appeal on its merits. The court directed the appellate authority to consider and dispose of the appeal accordingly.

Important Note: This decision emphasizes the importance of proportionality and fairness in dealing with procedural errors. While adherence to procedures is essential, minor errors, especially those rectified promptly, should not lead to the dismissal of appeals and denial of justice. The court’s decision to prioritize the merits of the appeal over a technical error ensures that taxpayers have a fair opportunity to present their case and that disputes are resolved based on substantive issues rather than procedural lapses.

HIGH COURT OF BOMBAY
Narendra Hirawat
v.
State of Maharashtra
M.S. Sonak and Jitendra Jain, JJ.
WRIT PETITION (L) NO28395 OF 2023
DECEMBER  16, 2024
Rahul Thakar and C.B. Thakar for the Petitioner. Ms. Jyoti Chavan, Addl. GP for the Respondent.
ORDER
1. Heard learned counsel for the parties.
2. Rule. The Rule is made returnable immediately at the request of and with the consent of the learned counsel for the parties.
3. The petitioner has instituted the appeal before the appellate authority against the order dated 25 April 2022. However, inadvertently, while filing the appeal online, as against the column indicating predeposit, no amount was indicated.
4. After this error was realized, the petitioner did make the 10% mandatory pre-deposit from the electronic cash ledger. However, by ignoring this compliance and holding the petitioner to the inadvertent error, the appellate authority has dismissed the petitioner’s appeal by order dated 13 April 2021.
5. Since the pre-deposit has been made, we agree with the learned counsel for the petitioner that such a rigid stand should not have been adopted. This was a case of an inadvertent error and the dismissal of the petitioner’s appeal even after the error was corrected, is excessively disproportionate.
6. Accordingly we set aside the impugned order dated 13 April 2023 and restore the petitioner’s appeal before appellant authority. Now that the pre-deposit has already made, the appellate authority must consider and dispose of the petitioner’s appeal on merits and in accordance with law.
7. The rule is made absolute in the above terms, and there shall be no cost order.
8. All concerned must act on an authenticated copy of this order.
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