2026 (3) TMI 1041

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....it petition is taken up for disposal at the admission stage itself. 4. The learned counsel for the petitioner would submit that in this case, initially, the show cause notice dated 27.05.2025 was issued and the impugned order dated 28.11.2025 was passed by the respondent for the issue, pertaining to the difference in Form GSTR-2A and GSTR-3B, whereby, the disputed tax amount was quantified as a sum of Rs. 87,524/-. Subsequently, once again, the respondent had issued another show cause notice dated 21.08.2025 and passed the impugned order dated 08.12.2025 for two issues, out of which, one is pertaining to the very same issue, viz., the difference in Form GSTR-2A and GSTR-3B, which was already covered vide earlier order dated 28.11.2025. I....

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....ed the entire materials available on record. 9. In the case on hand, initially, the impugned order dated 28.11.2025 was passed by the 1st respondent for only one issue pertaining to the difference in Form GSTR-2A and GSTR-3B. Subsequently, the impugned order dated 08.12.2025 was passed by the 2nd respondent for two issues, out of which, one is very same issue, viz., the difference in Form GSTR-2A and GSTR-3B, which was already covered by earlier order dated 28.11.2025. Hence, it is clear that two impugned orders dated 28.11.2025 and 08.12.2025 were passed for the very same issue, which leads to duplication of proceedings and double taxation. 10. When such being the case, as rightly contended by the petitioner, the earlier order dated ....