2024 (9) TMI 54

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....orari or any other appropriate writ, order or direction in the nature thereof quashing the repeated audit memos issued on various dated like 11.01.2024, 13.01.2024, 03.07.2024 and 23.07.2024 issued by Respondent No. 3 for being barred by limitation as prescribed under sub-section (4) of section 65 of the Central Goods and Services Tax Act 2017. ii. Issue a writ of mandamus or any other appropriate writ, order or direction in the nature thereof directing the Respondent No. 3 to submit the original note sheet wherein the permission of the Commissioner under Section 65 (1) of the CGST Act was granted to carry out the audit of business of the Petitioner for the specific period i.e. 2017-18 to 2019-20 which was later extended to 2020-21....

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....f the Integrated Goods and Services Tax Act, 2017 (hereafter the IGST Act). 3. The impugned SCN has been issued purportedly pursuant to the finding of the audit conducted under Section 65 of the CGST Act/DGST Act. The petitioner claims that it filed an application for refund of tax for the months of October, 2017; January, 2018; and February, 2018. On 19.12.2019 the petitioner's case was referred to Anti-Evasion Wing to examine and investigate the petition's refund. Thereafter on 27.04.2021, respondent no.3 issued a notice to the petitioner for conducting the audit for the financial years 2017-18 to 2019-20. 4. In terms of the additional notice dated 22.04.2022, the audit period was extended to cover the financial year 2020-21 as well....