GST short-payment with GSTR-1 disclosure: remand for Section 73 reconsideration under the amnesty scheme despite mismatch.

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....In a GST short-payment dispute, the HC noted that once outward supply was correctly disclosed in GSTR-1, the corresponding tax still had to be paid in GSTR-3B for the relevant period, so mere invocation of the stricter provision did not by itself warrant interference. After considering the later amnesty framework and the GST Council material, the Court treated the matter as one arising from return-filing glitches and admitted-liability mismatch capable of examination under the lesser provision. The demand and penalty order was quashed and the matter remitted for fresh consideration.....