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Independent professional certification requires pleaded knowledge or complicity for criminal liability; untimely complaints remain barred by limitatio...
HC dismissed the writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
HC dismissed the writ petition challenging tax refund rejection, holding that the petitioner must first exhaust statutory appellate remedies under Section 107 of CGST Act before seeking judicial intervention. The court found the challenge premature, as the underlying adjudication order comprehensively addressed factual issues. The petitioner was directed to pursue the prescribed administrative appeal mechanism, thereby maintaining procedural propriety and preventing premature judicial interference in tax dispute resolution.
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