Appellate authority must address all issues, including non-service notice claims, u/s 74 of the UPGST Act.

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....Notice/summons issued by the Central Tax Authority whereas adjudication u/s 74 had been made by the State Authority - the initiation of the proceeding for imposition of tax and penalty was with the issuance of the notice under Section 74 as contained in Chapter XV of UPGST Act and the inquiry under Section 70 of the Act was independent - - It goes without saying that all issues being raised by the petitioner herein including the issue of non-service of notice before passing the order u/s 74 shall have to be adjudicated by the appellate authority without being influenced by any of the observations made. - HC....