2025 (10) TMI 716

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....er dated 09.09.2025 whereby the appeal was dismissed as being beyond limitation. 3. Contention of learned counsel for the petitioner is that no opportunity of hearing was granted while passing the order under Section 73 of the GST Act. It has also pointed out that in absence of any opportunity the order impugned cannot be sustained and this issue was dealt by the Division Bench of this Court passed in Writ Tax No.303 of 2024 [Mahaveer Trading Company vs. Deputy Commissioner, State Tax and Anr; 2024:AHC:38820-DB]. 4. Learned Standing Counsel, on the basis of the instructions, states that in so far as the issue of opportunity of hearing is concerned, no date was fixed for personal hearing. 5. Before adverting to the aforesaid submiss....

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....61;ान) अधिवक्ता फर्म उपस्थित हुए। नोटिस का स्पष्टीकरण प्रस्तुत किया गया जो निम्न (ii) "जारी नोटिस के अनुपालन में दिनांक 07/10/2022 को पुनः श्&#2352....

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....#2344; है. 8. Thus, it is established on record that on all three dates, the petitioner had been called to file its reply on the points specified in the respective show-cause notice issued. The petitioner submitted its reply on each occasion. Those replies have been extracted in the impugned order. After recording the reply submitted on 27.10.2022, the adjudicating authority has chosen to deal with the merits of the replies submitted and passed a merit order. 9. It transpires from the record, neither the adjudicating authority issued any further notice to the petitioner to show cause or to participate in the oral hearing, nor he granted any opportunity of personal hearing to the petitioner. 10. On quer....