2024 (4) TMI 770

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....plies Corporation by integrating the same with a central server. In respect of assessment period 2017-18, the petitioner received show cause notice dated 14.09.2023 with regard to discrepancies between the petitioner's GSTR 3B returns and the auto populated GSTR 2A. Such show cause notice was replied to on 10.10.2023 and 17.10.2023 by enclosing annexures. The impugned order was issued on 29.12.2023 in the said facts and circumstances. 2. Learned counsel for the petitioner contended that the discrepancy arose on account of about three reasons. The first of these was the issuance of credit notes by the petitioner to the recipient of services. Since it was the first year of implementation of GST statutes, learned counsel submitted that ....

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....etitioner has placed the GSTR 1 statement on record. As submitted by learned counsel for the petitioner, no entries are made with regard to credit / debit notes. Instead, in the heading relating to B2C, total invoice value of minus Rs. 15,58,21,210.14/- and total taxable value of minus Rs. 13,20,51,873/- is shown. In the reply of the petitioner to the show cause notice, it is stated that credit notes were erroneously reported as ITC. In the impugned order, the assessing officer dealt with the above contentions by recording the following findings: "The contention of taxpayer is, the above credit note for Rs. 4,08,39,428.00 was wrongly taken into in the ITC register for the month of January 2018, but on verification of the GSTR - 1, ....