2025 (6) TMI 1777

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....ther support services. The petitioner was served with a show-cause notice, dated 27.07.2024, for the tax period July, 2017 to March, 2021, calling upon the petitioner to show cause why certain turnovers should not be taxed. The show-cause notice sought an explanation from the petitioner, in relation to the following : (i). Non-payment of tax against supply of services made to SEZ unit on account of the failure of the petitioner to furnish proof of admittance for authorized operations in the Special Economic Zone certified by the Specified Officer during the tax period. (ii). Short-payment of tax against supplies made under SAC code 9963 during the tax period. (iii). Wrong availment of Input Tax Credit on invoices ....

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....urnovers and supplies made by the petitioner in various States, apart from the State of Andhra Pradesh. The 3rd respondent could not have clubbed all these turnovers as if these are supplies made in the State of Andhra Pradesh. The complaint of the petitioner is that, this aspect has not been considered at all by the 3rd respondent despite objections to this effect being filed by the petitioner. Apart from this, the petitioner also contends that the accounts certified by the Chartered Accountants, including certain Trial Balances had been rejected by the 3rd respondent without any justifiable reason. For this purpose, the petitioner would rely upon the observations of the 3rd respondent, wherein figures reported in certain places in the Tri....

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....on of turnover. The petitioner further contends that, in such circumstances, the 3^rd respondent, merely on the ground that, he was not accepting the turnovers shown by the petitioner had invoked the penal provisions without any justification. 9. The learned Standing Counsel, appearing for the 3rd respondent, contends that, all these issues had been considered by the 3rd respondent in their proper perspective. The learned Standing Counsel also contends that, the material relied upon by the 3rd respondent such as the Trial Balances and other accounts, had been obtained from the office of the petitioner itself and as such, the petitioner cannot resile from these documents as they reveal true facts and figures, in relation to the supplies m....