GST ‘No Reply Filed’ Error Madras HC Steps In to Protect Taxpayer Rights
If you’ve ever faced a GST demand order showing “No Reply Filed”, even after submitting a proper reply through the GST portal, you’re not alone. The Madras High Court has taken serious note of such errors and recently passed a key judgment directing reassessment in such cases.
Let’s break it down for taxpayers and consultants.
What Triggered the Court’s Intervention?
In W.P. No. 14863 of 2024, the petitioner had submitted a reply to a GST show cause notice (SCN) via the GST portal. However, the department passed an order treating it as if no reply was filed.
The issue:
- The GST portal did not generate an ARN.
- But the petitioner had proof of submission via screenshots and logs.
- The final order ignored this and treated the taxpayer as non-compliant.
What Did the Madras High Court Say?
The Court clearly held that:
“It is incumbent upon the Assessing Authority to verify the existence of the reply, even if the portal shows otherwise.“
Key Highlights of the Judgment:
- If a taxpayer has submitted a reply and has documentary evidence, the department must consider it.
- Dismissing the reply without verification amounts to violation of natural justice.
- The matter was remanded back for fresh adjudication, after giving proper opportunity.
📌 Legal Basis Cited:
- Article 226 (Writ jurisdiction)
- Section 75(4) of CGST Act, 2017 – Opportunity of hearing must be granted before adjudication.
Why Does This Happen on the GST Portal?
This error often occurs due to:
- Technical glitches in submission workflow
- No Acknowledgement Reference Number (ARN) being generated
- Lack of auto-confirmation on the back-end of GSTN
- Poor coordination between front-end portal interface and back-end processing
What Should You Do If This Happens?
If your reply doesn’t reflect or shows “No Reply Filed”:
- Immediately take screenshots of the submitted reply
- Save time-stamped documents and confirmation emails (if any)
- Raise a ticket on GST Self-Service Portal (www.gst.gov.in/help)
- File a representation or writ petition if a wrongful order is passed
Expert Tip
“In case the portal fails to generate ARN, always back up your reply PDF and take multiple screenshots. In critical matters, follow up with a physical submission or e-mail to the jurisdictional officer,” says CA R. Sundaram, GST litigation expert.
Similar Cases & Precedents
- GRT Hotels & Resorts Pvt. Ltd. v. Principal Commissioner – Similar direction to adjudicate afresh due to technical denial of hearing.
- Multiple High Court rulings affirm that portal errors should not defeat substantive rights.
Summary
Madras HC ruled that GST orders passed with “No Reply Filed” remark—despite actual reply submission—are invalid. The Court ordered reassessment, reinforcing taxpayer rights when digital glitches occur on the GST portal.
FAQ
Q1. Can I challenge a GST order if my reply was ignored?
Yes. Courts allow reassessment if you prove that a reply was filed but not considered.
Q2. Is ARN generation mandatory to prove submission?
Not always. Other proofs like screenshots, logs, and emails can be accepted.
Q3. What section of GST law mandates hearing before an order?
Section 75(4) of the CGST Act, 2017.
🔗 Related:
- GST Amnesty Scheme 2025: Latest Extension & Benefits
- GST Portal Troubleshooting: What to Do When You Face Errors
Final Thoughts
If you’ve received a GST order with the remark “No Reply Filed”, don’t panic. You have legal remedies. Ensure documentation, raise your grievance, and approach the High Court if needed. At Efiletax, we help you navigate GST disputes with expert guidance and timely filing.