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Issues: Whether the assessment order confirming excess input tax credit required interference in view of the conflicting returns relied on by the parties, and whether the matter should be remanded for reconsideration.
Analysis: The petitioner relied on GSTR 3B returns and the annual return to show reversal of input tax credit against credit notes, while the respondent placed different return copies on record and disputed such reversal. In view of this contradiction, the factual position could not be determined conclusively on the existing record and required fresh examination by the assessing authority.
Conclusion: The assessment order was quashed and the matter was remanded for reconsideration with liberty to the petitioner to file the relevant returns, followed by a personal hearing and a fresh order by the assessing officer.