S.161 CGST Act | Rectification Order Must Be Reasoned, Adverse Order Can Be Passed Only After Hearing Party: Delhi High Court

The Delhi High Court has clarified that an order in rectification proceedings under Section 161 of the CGST Act must be reasoned, and any adverse order can only be passed after affording a proper hearing to the affected party. This ruling reinforces the principles of natural justice and procedural fairness in GST administration. The court emphasized that a mere cryptic rejection of a rectification application is insufficient; detailed reasons must be provided. If the rectification adversely impacts the applicant, an opportunity to be heard is mandatory. This decision ensures that tax authorities follow due process and transparency when rectifying orders, protecting taxpayers' rights.