https://www.taxtmi.com/caselaws?id=799062 Rule 164(6)'s deadline for filing a GST amnesty waiver application is an essential mandatory condition, not a directory procedural requirement. Section 128A relief remains subject to prescribed conditions, and the time-bound scheme's deemed-approval mechanism links key timelines to the waiver application. Separately, full payment of the tax demand under an ex parte original order safeguards revenue interests and supports setting aside that order for fresh determination. The taxpayer must receive a reasonable opportunity of hearing before the fresh determination, while the mandatory amnesty-application deadline remains unaffected. en-us Wed, 19 Aug 2026 00:00:00 +0530 Wed, 16 Sep 2026 08:38:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799062 Rule 164(6)'s deadline for filing a GST amnesty waiver application is an essential mandatory condition, not a directory procedural requirement. Section 128A relief remains subject to prescribed conditions, and the time-bound scheme's deemed-approval mechanism links key timelines to the waiver application. Separately, full payment of the tax demand under an ex parte original order safeguards revenue interests and supports setting aside that order for fresh determination. The taxpayer must receive a reasonable opportunity of hearing before the fresh determination, while the mandatory amnesty-application deadline remains unaffected. Case-Laws GST Wed, 19 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799062