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The HC set aside the impugned order and remanded the matter to the Adjudicating Authority for fresh disposal of the show cause notice dated 27 December 2024 on its merits and in accordance with law. The court held that an advance ruling authority cannot decline to entertain a renewal application solely because a show cause notice was issued subsequent to the filing of that application; pendency must exist as of the date of filing. The Petitioner's objection invoking a prior binding advance ruling was noted, but substantive adjudication of the December 2024 notice was directed to be undertaken afresh by the Adjudicating Authority.
The HC set aside the impugned order and remanded the matter to the Adjudicating Authority for fresh disposal of the show cause notice dated 27 December 2024 on its merits and in accordance with law. The court held that an advance ruling authority cannot decline to entertain a renewal application solely because a show cause notice was issued subsequent to the filing of that application; pendency must exist as of the date of filing. The Petitioner's objection invoking a prior binding advance ruling was noted, but substantive adjudication of the December 2024 notice was directed to be undertaken afresh by the Adjudicating Authority.
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