Waiver claim under Rule 164(10) remanded for fresh consideration after denial of hearing and no appellate remedy.

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....The High Court dealt with a partial rejection of a waiver claim linked to belated filing of GSTR-9 and noted the absence of a specific appellate remedy against the waiver order. As the petitioner had not appeared despite notice, the Court held that one further opportunity should be granted to file a reply and supporting documents before the same authority. It set aside the impugned order and remanded the matter for fresh consideration, leaving all factual and legal contentions open. No finding was rendered on the merits of the waiver claim under Rule 164(10), and the request was to be reconsidered in light of the clarifications in Circular No. 238/32/2024-GST.....