Hi I have a situation that, the Company had undergone departmental audit for FY 2018-19 to FY 20-21. Wherein we made submissions to the query raised. However, the response was not accounted for and DRC-01 was issued in December 2023 and personal hearing was granted. The Company didnot respond to the SCN and personal hearing and then order was issued in April 2024. The Company filed rectification in July 2025 and the rectification application is still pending for order. The response was not made or not informed due to change in the consultant of the Company. The notice is completely vague as same issued are demanded twice or twice. What remedy do the Company have now.
Remedy Against GST Adjudication Order After Expiry of Appeal Limitation Where Rectification Application Is Pending and SCN Contains Duplicate/Vague Demands
Where GST appeal limitation has expired, Article 226 writ jurisdiction is identified as a proposed remedy where audit submissions were allegedly disregarded and the show-cause notice contains vague or duplicate demands. Urgent disposal of a pending rectification application is emphasised, with duplicate demands characterised as arithmetical errors. The pendency of rectification is also treated as relevant to appeal limitation and recovery action, while timely appellate remedies may remain material to writ maintainability. (AI Summary)
TaxTMI
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