Held - It transpires that no reply to the “SCN” was ever submitted by the petitioner. Even the date of personal hearing was fixed four times i.e., on 27.10.2022, 25.11.2022, 07.12.2022 and 04.01.2023, however, the petitioner did not respond to the same.

It is further evident that the Assessee was given ample opportunity to appear before the adjudicating authority but he failed to do so. The letters of personal hearing were issued to him on the address “M/s Rajeev Kumar, Lukiya Petarwar, Bokaro Steel City, 827001” provided by petitioner-assessee in their GST registration but the letters were returned undelivered. It further transpires that the letters were also sent to the assessee through e-mail ID i.e. rajeevkumar020180@gamil.com which was available to the department but the Assessee did not respond to the said letters. Thus, the contention of the Assessee that principle of natural justice has not been complied is misplaced and misconceived and without any basis. As a matter of fact, in para-9 and 10 of the impugned Order-in-Original, the adjudicating authority has clearly stated giving details of opportunity provided to the Assessee. As such the contention of non-fulfillment of natural justice is not sustainable in the background of this case.

Accordingly, we are of the considered opinion that no error has been committed by the adjudicating authority in passing the impugned Order-in-Original, inasmuch as, enough opportunities were provided to the petitioner by issuing SCN and also fixing date of personal hearing for four times; but the petitioner did not respond to either of them.