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Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Availability of an efficacious alternative statutory remedy precluded writ relief: the High Court declined to examine merits because the petitioner had not availed the statutory appeal under Section 107 of the CGST Act read with Rule 109A. Complaints of non-supply of relied documents, defective service and service dates of summons, alleged non-consideration of replies and non-application of mind were held to arise from the adjudicatory record and fall within the scope of the statutory appellate forum; petition dismissed with liberty to pursue the prescribed appeal.
Availability of an efficacious alternative statutory remedy precluded writ relief: the High Court declined to examine merits because the petitioner had not availed the statutory appeal under Section 107 of the CGST Act read with Rule 109A. Complaints of non-supply of relied documents, defective service and service dates of summons, alleged non-consideration of replies and non-application of mind were held to arise from the adjudicatory record and fall within the scope of the statutory appellate forum; petition dismissed with liberty to pursue the prescribed appeal.
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