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2024 (3) TMI 337

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....es who appeared in this case: For the Petitioner: Mr. P. K. Gambhir & Mr. Rakesh Kumar, Advocates. For the Respondents: Mr. Rajeev Aggarwal, ASC for R-1 & 2. JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 28.12.2023, whereby the impugned Show Cause Notice dated 23.09.2023, proposing a demand against the petitioner has been disposed and a demand of Rs. 51,64,782.00....

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....of the heads. 4. The impugned order, however, after recording the narration, records that the reply uploaded by the taxpayer is not satisfactory. It merely states that: "And whereas. in response to the DRC-01, the Taxpayer submitted his reply in DRC-06 and the reply of the registered person as well as data available on GST Portal has been checked/examined and the reply/submission of the Taxpaye....

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....y is not satisfactory which exfacie shows that Proper Officer has not applied his mind to the reply submitted by the petitioner. 6. Further, if the Proper Officer was of the view that reply was not satisfactory and further details were required, the same could have been specifically sought from the petitioner, however, the record does not reflect that any such opportunity was given to the petitio....