2026 (3) TMI 967

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... GST Act, 2017 in respect of financial year 2021-2022 and demand order dated 08.10.2024 issued by the respondent No.4 demanding the tax, interest and penalty for the financial year 2021-2022 and 2022-2023 amounting to Rs. 18,10,762/- and Rs. 34,44,384/- respectively. 2. The tax returns of the petitioner for F.Y. 2021-2022 and 2022-2023 were scrutinized in the year 2024 under the Scrutiny Campaign. Thereafter, notices under Section 61 of the GST Act dated 03.06.2024 in form GST ASMT-10 were issued to the petitioner by the respondent No.4 seeking explanation regarding the discrepancy observed by the Proper Officer regarding the mismatch of TDS credit and turnover reported in GSTR-1/3B amounting to the tune of Rs. 92,01,039/- and Rs. 1,31,0....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Patanjali Ayurved Limited Vs. The State of Madhya Pradesh reported in [2024] 68 Taxlok.com 123 (MP) and Allahabad High Court in the case of Shri Sai Palace Vs. The State of Uttar Pradesh and Others reported in [2024] 69 Taxlok.com 182 (Allahabad), wherein the writ petition was entertained on the ground that no opportunity of personal hearing was provided to the assessee before passing Order-in-Original. Appreciation & Conclusions 7. In the present case, the petitioner did not submit any response to the initial two notices issued under Section 61 of the GST Act. Thereafter, two further notices were issued under Section 73 of the Central Goods and Services Tax Act, 2017, and the petitioner did not submit any response. Hence, the petiti....