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    <title>2026 (9) TMI 1473 - GSTAT BENGALURU</title>
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    <description>Revisionary proceedings under the Karnataka State GST Act remain within the three-year limitation period after excluding the pandemic-related period from 15 March 2020 to 28 February 2022, which applies to judicial, quasi-judicial and departmental proceedings. Penalty for movement of goods was restored because the goods were unloaded at a location not covered by the available tax invoice and e-way bill. Required delivery documents were generated only after interception, and the asserted technical glitch was unsupported by evidence. These circumstances established a wilful attempt to evade tax rather than a minor procedural lapse, leaving the statutory penalty operative.</description>
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