The Calcutta High Court, in LGW
Industries Limited v. Assistant Commissioner of Revenue, State Tax & Ors.,
examined the maintainability of a writ petition challenging an adjudication
order passed under Section 74 of the West Bengal Goods and Services Tax Act,
2017, for the financial year 2020–21. The petitioner assailed the adjudication
order dated 19 July 2024 on the grounds that it had been passed without
granting an opportunity of personal hearing, without permitting the filing of
written submissions, and without allowing cross-examination of witnesses whose
statements were relied upon by the department.
The petitioner contended that denial of
cross-examination and opportunity of hearing amounted to a violation of
principles of natural justice, warranting interference under Article 226 of the
Constitution. The adjudication order revealed that show cause notices in Form
GST DRC-01 had been issued and that the petitioner had sought adjournment and cross-examination
of multiple persons whose statements formed part of the investigation record.
The adjudicating authority, after considering the request, rejected the plea
for cross-examination on the ground that the statements were corroborative in
nature and that joint hearings and verifications had already been conducted in
the presence of the petitioner’s authorised representatives.
The High Court noted that the adjudication
order had been passed under Section 74 of the GST Act, which provides a complete
statutory mechanism of appeal under Section 107. The Court reiterated the
settled principle that where an efficacious alternative remedy is available,
the writ jurisdiction of the High Court ought not to be invoked, except in
exceptional circumstances. It was held that the petitioner had failed to
demonstrate any such exceptional circumstance warranting bypass of the
appellate remedy.
The Court further observed that allegations
relating to denial of cross-examination and opportunity of hearing could be effectively
examined by the appellate authority under the statutory framework. In view of
the availability of a clear and adequate alternative remedy, the High Court
declined to entertain the writ petition.
Accordingly, the writ petition was disposed
of, with liberty granted to the petitioner to file an appeal under Section 107
of the GST Act within thirty days from the date of the order. The Court
clarified that dismissal of the writ petition would not prejudice the
petitioner’s right to pursue the statutory appellate remedy in accordance with
law. No order as to costs was made.
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