2023 (2) TMI 93

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....cate For the Opposite Parties : Mr. Sunil Mishra, A.S.C. for the Revenue ORDER 1. The challenge in the present petition is to a notice dated 19^th February 2022 issued by the Deputy Commissioner of CT and GST to the Petitioner requiring him to produce the documents related to stock retention and vehicles used in generation of e-way bills for inward and outward supplies as well as to the i....

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....states in para 6 of the present petition that payment of the demanded tax was made "on protest in order to release the detained vehicle", the fact remains that no such letter recording any 'protest' has been produced before this Court. It certainly was not made at the time of payment. What has been shown to the Court is a letter written by the Petitioner to the Department on 6th July 2022 disownin....

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.... open to a person against whom a demand is raised to make a 'partial payment' and also to "file any submissions against the proposed liability" in Part-B of Form-GST DRC-01A. The Petitioner did not opt for the above procedure. Instead, he made the full payment of the tax demanded by the Department without any protest. It is only three months after making such payment that he chose to write a lette....

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.... As you have paid the amount of tax and other dues mentioned in the notice along with applicable interest and penalty in accordance with the relevant provisions of Act, the proceedings initiated vide the said notice are hereby concluded. Signature: Name: PRAN SHANKAR DEOTA Designation/Status:Deputy Commissioner of CT & GST Jurisdiction: Odisha 7. Initially, Mr. Pattanaik, learned....