2024 (3) TMI 1131

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....Prashant Shukla and Mr. Rajneesh Kumar Verma, Advocates. For the Respondents: Mr. Rajiv Aggarwal, ASC JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 30.12.2023, whereby the impugned Show Cause Notice dated 23.09.2023, proposing a demand against the petitioner has been disposed of and a demand of Rs. 57,11,36,600.00 including penalty has been raised against the p....

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....f 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, a notice for personal hearing was also issued to the taxpayer along with notice DRC 01 to explain their reply/objections against proposed amount of tax and interest. And whereas, the* taxpayer has filled his/her repl....

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....itioner. However, the record does not reflect that any such opportunity was given to the petitioner to clarify its reply or furnish further documents/details. 7. In view of the above, the order cannot be sustained, and the matter is liable to be remitted to the Proper Officer for re-adjudication. Accordingly, the impugned order dated 30.12.2023 is set aside. The matter is remitted to the Proper....