2023 (11) TMI 711

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....the Respondent No.3, Assistant Commissioner, Central Goods & Service Tax, Division-I, E-23B, Sector-8, Noida, as also the consequential order dated 27.02.2023 passed by the Respondent No.2, Principal Commissioner, Central Goods & Service Tax Commissionerate, Noida , C-56/42, Sector-62, Noida, whereby and whereunder M/s TSR Subramanian, a Sole Proprietorship Firm run by the husband of the petitioner namely late Sri T.S.R. Subramanian, engaged in providing services as a Consultant has been saddled with tax liability of Rs. 8,97,716/- under the proviso to Section 73(1) of the Finance Act, 1994 read with Sections 142, 173, 174 of the Central Goods & Service Tax Act, 2017 towards Service Tax for the Financial Year 2014-15 along with equivalent p....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....and the impugned order is ex-parte and against a dead person. It is also argued that the impugned demand cum show cause notice dated 26.03.2021 on the basis of which the impugned order dated 27.02.2023 has been passed, pertains to Financial Year 2014-15 and as such, the entire proceedings are patently illegal having been initiated after a period of five years from the relevant date. It is, accordingly, submitted that the impugned order is liable to be set aside. Sri Amit Mahajan, learned counsel appearing for the contesting respondents has attempted to justify the order on the ground that the impugned order has been passed against the firm M/s TSR Subramanian. He, however, has not been able to refute the submissions of learned counsel fo....