2026 (4) TMI 362

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.... Petitioner: Sri Singam Srinivasa Rao, Learned Counsel. For the Respondent Nos. 1 and 2: Mr. Dominic Fernandes, Learned Senior Standing Counsel for Central Board of Indirect Taxes and Customs (CBIC). ORDER: Heard Sri Singam Srinivasa Rao, learned counsel for the petitioner and Mr. Dominic Fernandes, learned Senior Standing Counsel for Central Board of Indirect Taxes and Customs (CBIC) app....

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....d filed returns using GSTIN 32ZA resulting in mismatch between the GSTR-3B and GSTR-2A/2B. The supplier made certain amendments in the GST portal in GSTIN applied for 2017-18. However, the respondent issued Form GST DRC-01A proposing demand of Rs.15,37,411=74 alleging excess ITC for 2017-18. Despite submission of a reply and explaining the mismatch due to the dual GSTIN issue and suppliers errors ....

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....14 of the Limitation Act, 1963 for the purposes of preferring an appeal. Learned counsel for the petitioner has therefore sought to assail the impugned orders on merits as well. 5. Learned Senior Standing Counsel for CBIC submits that the reply referred to by the petitioner is to Form GST DRC-01A, the intimation prior to issuance of show cause notice. He has however not submitted any reply to t....