2025 (7) TMI 1065

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....APPL. 33370/2025, W. P. (C) 7488/2025 & CM APPL. 33427/2025, CM APPL. 33428/2025 - -<br>GST<br>JUSTICE PRATHIBA M. SINGH AND JUSTICE RAJNEESH KUMAR GUPTA For the Petitioner Through: Mr. A.K. Babbar & Mr. B.K. Tripathi, Advs. For the Respondents Through: Ms. Arunima Dwivedi, CGSC with Mr. Sainyam Bhardwaj, Advs. Mr. Pranay Mohan Govil, SSC. ORDER PER 1. This hearing has been done throug....

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....mary order dated 22nd February, 2025 (in FORM GST DRC-07) bearing reference number ZD070225054692E vide W.P.(C) 7465/2025 and W.P.(C) 7488/2025 4. The submission of Mr. Babbar, ld. Counsel appearing on behalf of the Petitioners is the following: i) That the DRC-07 having been uploaded on 22nd February, 2025, the same is barred by limitation; ii) The penalty has been imposed be....

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....ofile of the tax payers. The screenshots handed over by the ld. Counsel for the Respondents are taken on record. 7. Thus, insofar as the first issue of limitation is concerned, at this stage, the Court prima facie is of the opinion, that the same is not barred by limitation. Insofar as the second issue of penalty being levied beyond what is permissible limit prescribed under Section 122 of CGST....

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....d as being barred by limitation. The Petitioners are free to raise all the contentions, on merits, including the quantum of tax as also the ground of limitation before the Appellate Authority. The appeals shall be adjudicated by the Appellate Authority on merits without being influenced by the observations in this order. 10. Mr. Babbar, ld. Counsel at this stage submits in W.P.(C) 7465/2025, th....