Pre-decisional notice and hearing under GST refund rules are mandatory; appellate review cannot cure their absence.

Pre-decisional notice and hearing under GST refund rules are mandatory; appellate review cannot cure their absence.
Case-Laws
GST
Rule 92(3) requires Form GST RFD-08 notice, consideration of the refund applicant's reply, and a pre-decisional hearing before accumulated input tax credit refunds may be wholly or partly rejected. These safeguards identify the alleged input tax credit mismatch and permit a specific response. An appellate hearing cannot replace those mandatory steps. Refund rejections issued without them are void from inception and require fresh processing, with substantive eligibility issues remaining open.
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