Laches and admitted tax liability barred writ challenge to assessment order after mismatch between GSTR-1 and GSTR-3B

A writ petition challenging an assessment order was held not entertainable because it was filed long after the statutory period. The Court noted that the taxpayer had replied to the notices, ed the defect, and admitted the tax payable. It also recorded a mismatch between turnover reported in GSTR-1 and GSTR-3B, which resulted in short payment of tax. In these circumstances, no ground existed to interfere with the assessment order, and the petition was dismissed for laches and admitted tax liability.

---

---

Issues: Whether the writ petition challenging the assessment order was liable to be entertained despite being filed beyond the statutory period and in the face of the petitioner's admitted tax liability.

Analysis: The challenge was raised long after the assessment order. The order recorded that the petitioner had replied to the notices and had accepted the defect, acknowledging the tax payable. The Court also noted a mismatch between the turnover reported in GSTR-1 and GSTR-3B, resulting in a short payment of tax. In these circumstances, no ground was made out to interfere with the assessment order.

Conclusion: The writ petition was not entertainable and stood dismissed on the ground of laches as well as the petitioner's admission of tax liability.

---