Petition dismissed; Section 73 SCN must be contested before assessing authority; ITC denied for invoices without receipt

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....The HC dismissed the petition and upheld the impugned order-in-original dated 28.02.2025 passed by Respondent No.2, concluding that the petitioner unlawfully availed ITC on invoices without receipt of goods/services and that part payments of tax, penalty and interest had been made between 23.11.2021 and 06.01.2024. The court held the DGGI investigation did not constitute commencement of proceedings and emphasized the petitioner's duty to contest the show-cause notice issued under Section 73 before the assessing authority; failure to do so precluded relief. The DGGI's limited conclusion on certain suppliers was without prejudice to further action by jurisdictional officers. Petitioner granted liberty to pursue statutory appellate remedies.....