2025 (12) TMI 1439

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....rs and as the issue involved is common hence both the petitions are being decided by this common order. 3. In Writ Tax no.1197 of 2025, the order impugned is dated 25.09.2025 whereby the appeal preferred by the petitioner for assailing the order dated 19.04.2024 relating to financial year 2018-19 has been dismissed on the ground of delay. In the connected petition bearing no.1224 of 2025 the order in appeal is also dated 25.09.2025 whereby the appeal preferred by the petitioner against the order dated 13.08.2024 relating to the financial year 2019-20 has been dismissed again on the ground of delay. 4. Submission of learned counsel for the petitioner in both the petitions is that the petitioner was not granted an adequate opportunity o....

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....h huge liability is sought to be pressed against the assesse then the least requirement is to afford an adequate opportunity of hearing coupled with the fact that the appeal has been dismissed on the ground of delay without even considering any plea raised by the petitioner and thus the right of the petitioner has been curtailed. In such circumstances, the orders are apparently voilative of Article 14, hence, deserves to be set aside. 8. Sri Sanjay Sarin learned Additional Chief Standing counsel has urged that the notices which were issued to the petitioner under Section 73 of the The Uttar Pradesh Goods and Services Tax Act though the date of filing of reply and the date of personal hearing was same but that may not come to the aid of t....