Recovery Proceedings Stayed in GST: Assessee’s Belated Reply to be Considered If Recovery Proceeding Has Not Yet Neen Initiated

By | February 8, 2025

 Recovery Proceedings Stayed in GST: Assessee’s Belated Reply to be Considered If Recovery Proceeding Has Not Yet Neen Initiated

Summary in Key Points:

  • Issue: Should recovery proceedings be stayed and the assessee’s belated reply be considered?

  • Facts: The assessee received a notice for recovery of interest arrears with a reply deadline of July 9, 2024. They filed a belated reply on November 11, 2024. The assessee sought a direction for their reply to be considered. The respondent authority confirmed that recovery proceedings had not yet been initiated.

  • Decision: The court directed the respondent authority to consider the assessee’s belated reply. Until a decision is communicated to the assessee, no recovery proceedings should be initiated.

Important Note: This decision demonstrates the court’s inclination towards granting taxpayers a fair opportunity to present their case, even if they miss the initial deadline. By directing the authority to consider the belated reply and staying recovery proceedings, the court ensures that the assessee’s response is duly considered before any coercive action is taken. This ruling promotes a balanced approach that protects the interests of both the revenue and the taxpayer, preventing undue hardship while allowing for a proper assessment of the assessee’s response.

HIGH COURT OF ORISSA
Indera Motors
v.
Commissioner of Commercial Taxes, CT and GST
Arindam Sinha and M.S. Sahoo, JJ.
W.P.(C) No.30592 of 2024
DECEMBER  17, 2024
S. Ray, Sr. Adv., K.K. Sahoo and D.K. Samal, Advs. for the Petitioner. S. Mishra, Standing Counsel for the Respondent.
ORDER
1. Mr. Ray, learned senior advocate appears on behalf of petitioner and submits, notice dated 25th June, 2024 was issued for recovery of arrears amounting to Rs.64,56,777/- towards interest. Reply was to be filed by 9th July, 2024. His client filed reply dated 11th November, 2024, received by the office on 13th November, 2024. Prayer of his client is for direction upon the authority to consider the reply.
2. On earlier occasion on behalf of revenue adjournment was obtained to get instructions. Mr. Mishra, learned advocate, Standing Counsel appears on behalf of revenue and draws attention to said notice dated 25th June, 2024 and submits, it will appear from it that personal appearance was to be on 9th July, 2024, when the reply would have been accepted. Petitioner appeared and sought for time. Furthermore, his oral instructions are, recovery proceedings have not yet been initiated.
3. We have already noticed petitioner’s contention is the reply was filed out of time and it be considered. Since recovery proceeding has not yet been initiated, we direct opposite party no.2 to consider petitioner’s reply dated 11th November, 2024, received on 13th November, 2024. Order be made informing petitioner on his contentions in the reply. Till before such order is communicated to petitioner, there should not be recovery proceeding initiated.
4. The writ petition is disposed of.
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