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of Rule 39(1)(a) validity: Rule 39(1)(a) impermissibly adds a mandatory monthly time-limit for ISD distribution beyond Section 20's delegated 'manner' power, extinguishing vested ITC rights and violating Article 14; consequence - Rule 39(1)(a) struck down. Natural justice: audit finalization and placement before MMCM without granting requested time or hearing breached principles of natural justice; consequence - Final Audit Report and related proceedings quashed. Time limitation/suppression: show-cause issued beyond normal limitation under s.73; invocation of extended period under s.74 on alleged suppression unsustainable where returns disclosed distributions on the portal; consequence - proceedings untenable. Maintainability: writ entertained despite alternative remedy due to vires and natural-justice challenge. - HC
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