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The court held that the petitioner was denied the principles of natural justice by not being given a reasonable opportunity to contest the tax demand on merits regarding the difference between GSTR 3B and GSTR 1, and the RCM liability mismatch. The petitioner provided proof of payment for the GSTR 3B and GSTR 1 difference, and substantiated the RCM liability mismatch as an inadvertent error through GSTR 3B returns, securing the revenue interest. The impugned order relating to RCM liability mismatch was set aside, and the matter was remanded for reconsideration by the respondent authority. The petitioner was directed to submit a reply to the show cause notice within 15 days. The petition was disposed of.
The court held that the petitioner was denied the principles of natural justice by not being given a reasonable opportunity to contest the tax demand on merits regarding the difference between GSTR 3B and GSTR 1, and the RCM liability mismatch. The petitioner provided proof of payment for the GSTR 3B and GSTR 1 difference, and substantiated the RCM liability mismatch as an inadvertent error through GSTR 3B returns, securing the revenue interest. The impugned order relating to RCM liability mismatch was set aside, and the matter was remanded for reconsideration by the respondent authority. The petitioner was directed to submit a reply to the show cause notice within 15 days. The petition was disposed of.
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