2024 (4) TMI 286

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....his case: For the Petitioner: Mr. Rajesh Mahna, Mr. Ramanand Roy, Mr. Mithlesh Kumar Tiwari, Mr. Mayank Kouts, Mr. Shiva Narang and Mr. Silky Wadhwa, Advocates For the Respondents: Mr. Rajiv Aggarwal, ASC with Ms. Samridhi Vats, Advocate JUDGMENT SANJEEV SACHDEVA, J. (ORAL) 1. Petitioner impugns order dated 25.12.2023, whereby the impugned Show Cause Notice dated 26.09.2023, proposi....

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....e said Show Cause Notice, a detailed reply was furnished by the petitioner giving disclosures under each of the heads. 4. The impugned order, however, after recording the narration, records that the reply uploaded by the taxpayer is insufficient and unsatisfactory. It merely states that "And whereas, the Taxpayer filed reply/explanation on dated 23.10.2023 and 26.10.2023. And whereas, reply fil....

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....gistration. The same was found not satisfactory as per the detail given below." The Proper Officer has opined that the reply is insufficient and unsatisfactory. 5. The impugned order does not specifically deal with the reply dated 23.10.2023 given by the petitioner, however, refers to certain judgment to hold that the burden to prove admissibility of any input tax credit cannot be shifted to th....