O R D E R

This Writ Petition is filed challenging the impugned order dated

10.12.2025.

2. Upon hearing the learned counsel for the petitioner and upon perusal of the impugned order, it is seen that when there was a mismatch between GSTR-3B and GSTR-9, along with non-reversal of common credit attributable to exempt supplies, the petitioner did not avail the opportunity when the show cause notice and personal hearing notices were issued. Accordingly, the impugned order came to be passed ex parte.

3. It is the contention of the petitioner that since the show cause notice as well as the personal hearing notices were uploaded on the web portal and no physical service of the notices was effected, the petitioner was unaware of the same. The petitioner is a small trader with limited familiarity with the technical aspects of GST compliance and portal-based communication and had been depending upon a part-time accountant for filing returns and monitoring portal communications. Since the said accountant failed to inform t