2025 (12) TMI 1136

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....31.12.2018 in connection with show cause notice dated 30.04.2021, the petitioner has come up before this Court invoking provisions under Articles 226 and 227 of the Constitution of India. 2. It is the case of the petitioner that CT & GST Organisation, under a mistaken notion of fact proceeded to assess the present petitioner, namely, "Subrat Rout". 3. Mr. Deba Priya Mishra, learned Advocate submitted that the petitioner asserted that he has not received any payment in respect of the alleged work to have been executed during the aforesaid tax periods. At the time of initiation of adjudication process under Section 73 of the GST Act, the petitioner's registration granted under GST Act had already stood cancelled. Therefore, the petition....

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....ously urged to quash the adjudication order dated 27.07.2021. 4. Mr. Seshadeb Das, learned Additional Standing Counsel for the CT & GST Organisation, upon instruction received from Deputy Commissioner of CT & GST, CT & GST Circle, Cuttack-1 City, Cuttack, submitted that the mismatch was found in the figures disclosed in the returns GSTR-2A and GSTR-3B. Accordingly, notices were issued. Since there was no response, the proceeding under Section 73 of the GST Act was culminated in demand. Since no further proceeding was pending, show cause notice for recovery of outstanding amount was issued. He fairly conceded that the Department has admitted the error of fact and furnished the written instruction wherein the following is found recorded: ....