Gujarat GST recovery u/s 78 requires timely action and a mandatory hearing opportunity per Section 75(4).

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....Initiation of recovery proceedings - time limitation - Section 78 of Gujarat GST Act - Section 75(4), referred to above, makes it abundantly clear that an opportunity of hearing has to be given, more particularly, in those cases where a request is received in writing from the person chargeable with tax or penalty and without any adverse decision is contemplated against such person. - HC....