Refund Rejection and Principle of Natural Justice

The Court held that denial of personal hearing and issuance of a show cause notice with a truncated response timeline vitiates refund adjudication under GST. 

It reaffirmed that Rule 92(3) mandates both adequate time and opportunity of hearing before rejection of refund. The entire proceedings were quashed and remanded for fresh consideration, emphasizing procedural fairness as indispensable in tax adjudication.