2026 (1) TMI 1138

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....itioner(s) No. 1: Mr Devan Parikh, Senior Advocate with Mr Manish Mishra, Mr Rajan Mishra, Mr Arvind Parikh For J Sagar Associates (8162)   For the Respondent(s) No. 1,2: Mr CB Gupta (1685). ORAL ORDER (PER : HONOURABLE MR. JUSTICE A.S. SUPEHIA) 1. On 24.12.2025, this Court has passed the following order: "1. Learned Senior Standing Counsel Mr. C.B. Gupta on instructions ....

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....rned Senior Standing Counsel Mr. C.B. Gupta the matter is to be adjourned. 3. Learned Senior Standing Counsel Mr. Deven Parikh has further submitted that infact the conciliation report is given on 11.08.2025, 13.10.2025 and 14.10.2025. 4. Issue Notice returnable on 07.01.2026. Learned Senior Standing Counsel Mr. C.B. Gupta waives service of notice on behalf of respondents. ....

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....page No.86 of the impugned order), it is specifically recorded that "... ... ... However, no such reconciliation statement in respect of such MIS report generated from SAP system has been submitted by the taxpayer to this office... ... ...", appears to be incorrect and contrary to the record. 4. Thus, on this short issue, the impugned order dated 16.10.2025 to the extent of observations made in....

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....impugned order), which is as under: "Therefore, in view of the above, I find that the taxpayer has intentionally reported less turnover in their GSTR returns on which they are required to pay the tax amount along with applicable interest and penalty." 7. From a bare perusal of the aforesaid observation made by the adjudicating authority, we find that the contention raised by the petiti....