Tribunals, taxpayers, and the state: a comparative analysis of GST adjudicatory frameworks in India, Australia, and Canada

This research conducts a comparative analysis of Goods and Services Tax (GST) adjudication frameworks in Australia, Canada, and India, examining how these systems shape state-taxpayer relations. As GST regimes become increasingly pervasive in federations, their long-term effectiveness depends significantly on the credibility, independence, and accessibility of their dispute resolution bodies. Through a systematic doctrinal review of legislative statutes, tribunal designs, jurisdictional parameters, and judicial precedents, this study evaluates how principles of natural justice, due process, and administrative procedure are embedded within each system. The findings reveal substantial structural diversity. Australian and Canadian frameworks exhibit well-insulated, hierarchical, and procedurally coordinated approaches to dispute resolution, fostering greater institutional coherence. In contrast, India’s GST framework remains constrained by constitutional ambiguities, complex tribunal establishment processes, apprehensions of executive interference, and a fragmented appellate structure. Grounded in administrative justice and fiscal federalism theories, the study highlights institutional features critical to effective tax governance. The results underscore that the sustainability of GST systems is intrinsically linked to the reliability of their adjudicatory mechanisms. While the doctrinal methodology effectively addresses the research objectives, it is limited by its reliance on secondary sources and the absence of empirical data from taxpayer surveys or interviews, suggesting avenues for future research.