Allahabad HC Clarifies Scope of Section 93 of GST Act, Affirming Legal Heirs’ Liability but Invalidating Determinations Against Deceased Individuals

The Allahabad High Court addressed the application of Section 93 of the GST Act concerning the liability of legal heirs for dues of deceased taxpayers. The court clarified that while the Act explicitly holds legal heirs accountable for unsettled GST liabilities, any determination issued against a deceased individual posthumously is invalid. This judgment arose from a dispute where tax authorities sought to recover dues directly from a deceased taxpayer’s estate without considering procedural safeguards. The court highlighted that proper legal procedures must be followed to ascertain liability, ensuring heirs are formally notified and provided the opportunity to contest claims. It emphasized that the mere existence of Section 93 does not authorize authorities to bypass the basic principles of natural justice. The ruling reinforces the need for administrative prudence, transparency, and respect for due process, ensuring that enforcement does not arbitrarily burden deceased persons or their heirs. Legal and compliance teams are likely to refer to this judgment when assessing inheritance-related GST exposures, ensuring adherence to procedural correctness.