2022 (11) TMI 552

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.... Audit Team-1, CT & GST Circle, CU-II, Cuttack as well as the final audit report of the same date under Section 65(6) of the Orissa GST Act, 2017 (OGST Act). 3. Mr. Jagabandhu Sahoo, learned Senior Advocate appearing for the Petitioner, at the outset, draws attention to Rule 101(4) of the OGST Rules, 2017 which reads as under: "4. The proper officer may inform the registered person of the discrepancies noticed, if any, as observed in the audit and the said person may file his reply and the proper officer shall finalise the findings of the audit after due consideration of the reply furnished." 4. He points out that in the present case, there was no opportunity granted to the Petitioner to file a reply to the draft audit report....

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....IT" shall mean the date on which the records and other documents, called for by the tax authorities, are made available by the registered person or the actual institution of audit at the place of business, whichever is later. ....... 6. On conclusion of audit, the proper officer shall, within thirty days, inform the registered person, whose records are audited, about the findings, his rights and obligations and the reasons for such findings." 7. In view of the Explanation to Section 65 (4) of the OGST Act, the 3-month period within which the audit had to be completed commenced, in the present case, on 22nd March, 2022. In other words, the entire audit exercised had to be completed with the submission of final audit repo....