Held - Considering the peculiar facts situation in the instant case, namely that by way of a third party garnishee order, the entire tax demanded from the appellant have been recovered, we are of the view that the revenue will not be prejudiced if a fresh opportunity of personal hearing is granted to the appellant to put forth his submissions.

The submission of the learned advocate appearing for the respondents/State is that the interest of the revenue should be protected. In our view, the interest of the revenue has been sufficiently protected inasmuch as the entire tax demanded under the three impugned orders have been fully recovered by way of garnishee proceedings.

In the light of the above, the writ petitions as well as these appeals are disposed of by directing the appellant to treat the orders under Section 74(9) of the W.B.G.S.T. Act, 2017, which were impugned in the writ petitions as the show-cause notice and the appellant is directed to file his objections to the notice within 15 days from the date of receipt of server copy of this judgement and order.

On receipt of the objections/replies, the Deputy Commissioner, State Tax, Bardhaman Charge shall afford an opportunity of personal hearing to the appellant or his authorised representative and pass fresh orders on merits and in accordance in law. The amount, which have already been recovered by way of garnishee proceedings shall abide by the fresh orders to be passed in terms of the above directions.