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    <title>Assessment and recovery proceedings could not be sustained without consideration of factual and legal issues</title>
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    <description>The authority must re examine GST assessment and recovery notices where statutory notice requirements and procedural safeguards are disputed: prior scrutiny and show cause notices were alleged not to have been issued, and applicability of GST to unbilled revenue was contested. The impugned assessment and recovery notices were set aside and the matter remitted for fresh consideration on both factual and legal issues, with an opportunity for the taxpayer to file replies and supporting documents and with a direction for expeditious completion.</description>
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      <description>The authority must re examine GST assessment and recovery notices where statutory notice requirements and procedural safeguards are disputed: prior scrutiny and show cause notices were alleged not to have been issued, and applicability of GST to unbilled revenue was contested. The impugned assessment and recovery notices were set aside and the matter remitted for fresh consideration on both factual and legal issues, with an opportunity for the taxpayer to file replies and supporting documents and with a direction for expeditious completion.</description>
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