The Punjab & Haryana High Court has set aside a GST demand order holding that the adjudicating authority passed a non-speaking order without proper reasoning or consideration of the taxpayer’s reply.

The bench of Justice Deepak Sibal and Justice Parmod Goyal has observed that the authority acknowledged receipt of the reply dated 26.11.2025, yet failed to examine or discuss its contents.  The conclusion that no supporting documents were furnished was unsupported by any reasoning.  The order did not deal with any submissions or evidence filed by the petitioner. 

The bench emphasized that quasi-judicial authorities are duty-bound to provide reasons while rejecting a taxpayer’s submissions. An order lacking reasoning qualifies as a “non-speaking order” and is legally unsustainable.

The petitioner, Hudson Insurance Brokers Private Limited, engaged in insurance brokerage services, challenged an order dated 24.12.2025 passed by the Commercial Tax Officer, Chandigarh, which raised a GST demand of ₹13,42,051. 

The dispute originated from scrutiny proceedings under Section 61 of the Central Goods and Services Tax Act, 2017, where discrepancies were alleged in the returns for FY 2021–22. Despite submitting a reply in Form GST ASMT-11 along with documents, the department issued a show cause notice under Section 73(1), alleging that the response was inadequate. 

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Subsequently, the petitioner filed a detailed reply in Form GST DRC-06 on 26.11.2025 along with supporting documents. However, the authority proceeded to confirm the demand without adequately addressing the submissions. 

The central issue before the Court was whether the adjudicating authority violated principles of natural justice by passing the demand order without properly considering the taxpayer’s reply and evidence.

The Revenue argued that the writ petition was not maintainable due to availability of an appellate remedy. However, the Court reiterated settled law that writ jurisdiction under Article 226 can be exercised where principles of natural justice are violated, or the order lacks jurisdiction or reasoning.

The Court relied on precedents including Whirlpool Corporation v. Registrar of Trademarks and Radha Krishan Industries v. State of Himachal Pradesh to support this position. 

Allowing the writ petition, the High Court set aside the GST demand order dated 24.12.2025 and directed the adjudicating authority to grant a proper opportunity of personal hearing and pass a fresh, reasoned order after considering the reply and evidence.

Case Details

Case Title: Hudson Insurance Brokers Private Limited Versus Union Territory Of Chandigarh

Citation: JURISHOUR-940-HC-2026(P&H) 

Case No.: CWP-8559-2026

Date: 17/04/2026

Counsel For  Petitioner:  Krati Singh, Advocate

Counsel For Respondent: Sourabh Goel, Sr. Standing Counsel

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