2024 (5) TMI 656

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....tions. Such objections were not accepted. Therefore, an intimation was issued on 20.09.2023 in Form GST DRC-01. This was followed by a show cause notice dated 29.09.2023. The petitioner replied thereto on 26.12.2023. The impugned order dated 29.12.2023 was issued thereafter. 3. Learned counsel for the petitioner invited my attention to the intimation dated 20.09.2023 and show cause notice dated 29.09.2023. He pointed out that the audit observations were converted into the show cause notice and this is evident from the conclusions which are recorded in the show cause notice with regard to each alleged defect. By comparing the intimation and the show cause notice, learned counsel points out that the same language is contained in the show c....

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....dable. Due to non compliance of section 16(2)(c) of TNGST Act, 2017 the reply filed by the taxpayer is not accepted and the demand proposed in the defect is confirmed. Accordingly tax liability is worked out as below: Tax (Rs.) Penalty (Rs.) Interest IGST CGST SGST IGST CGST SGST IGST CGST SGST 9,43,609.00 4,74,057.00 4,74,057.00 94,360.00 47,405.00 47,405.00 Interest will be levied till the payment of tax. You are required to pay the above tax liability along with interest under Section 50 and penalty under Section 73(9) of TNGST Act 2017. " The above extract reveals that a conclusion was recorded instead of indicating the tax proposal and calling upon the petitioner to s....