Mere Non-Acceptance of Reply Does Not Amount to Natural Justice Violation: Madras HC Directs to Avail Appellate Remedy [Read Order]

The Madurai Bench of the Madras High Court held that mere non-acceptance of a taxpayer’s reply by the assessing authority does not constitute a violation of the principles of natural justice, especially when the reply has been considered and a statutory appellate remedy is available.

The petitioner, M.G.P. Store approached the High Court to quash an assessment order dated 28 November 2025.

The petitioner contended that although a reply had been submitted, the impugned order failed to properly deal with their contentions.

It was argued that the reply was not even enumerated in the reference column and was rejected without adequate reasoning.

The petitioner alleged the authority merely stated the reply was “not accepted” and passed the order because the taxpayer skipped the personal hearing, reflecting a non-application of mind.

On the other hand, the State contended that the order clearly indicated the reply had been verified and considered. The government submitted that the authority’s decision not to accept the explanation does not imply the reply was ignored.

It was further argued that the GST Act provides an effective appellate mechanism, and the petitioner should pursue that rather than invoking writ jurisdiction.

Justice D. Bharatha Chakravarthy observed that the order contained references to the petitioner’s reply.

The Court noted that the petitioner had submitted a written response but chose not to appear for the personal hearing. Therefore, it held that a rejection of a reply does not equate to a violation of natural justice.

Therefore the high court refused to quash the assessment order and directed to take the alternative remedy within one week leaving merits of the matter open.

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