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The HC dismissed the belated application for rectification under s.161 as time-barred but observed that, prima facie, the petitioner may fall within the exemption under Serial No.20 of N.N. 2/2017-CT (Rate); however, the factual question whether the petitioner dealt in goods covered by that entry was held to be inappropriate for determination by the HC. The court quashed the impugned order and remitted the matter to the original authority for fresh adjudication, directing adjudication on terms and specifying provisional compliance by the petitioner of 25% of the disputed tax. The petition was disposed of by remand.
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