2026 (7) TMI 1921

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....ra, AGP. ORDER (PER : ADVAIT M. SETHNA, J.) :- 1. Heard the learned counsel for the parties and with their assistance, we have perused the record. 2. Rule. Rule made returnable forthwith with the consent of the parties. 3. This Petition is filed under Article 226 of the Constitution of India. The Petitioner has primarily assailed the rejection of its Appeal filed on 11th February 20....

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....e notice dated 2nd December 2025 was issued to the Petitioner for blocking of its ITC calling upon them to show cause as to why ITC of Rs.3,58,076.52 an interest and penalty thereon should not be blocked as per Rule 86A of the CGST/MGST Act read with Section 20 of the IGST Act. 7. Thereafter, on 13th December 2025, the Petitioner deposited Rs. 36,000/-, being 20% of the total amount of tax dete....

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....er, has preferred the present proceedings before this Court. 11. Mr. Jas Sanghavi, learned counsel for the Petitioner has drawn our attention to the Impugned Order (Exh.- 'A'). He would submit that the only reason for rejection in the Impugned Order is stated to be "Incorrect declaration of Order issuing Authority by Taxpayer". He would submit that the order does not contain any reasons in supp....

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....perusal of the Impugned Order clearly indicates that the rejection of the Petitioner's Appeal is merely recorded in one line i.e. "Incorrect declaration of Order issuing Authority by Taxpayer" which, to say least, is bereft of reasons. This is clearly indicative of a cryptic order. We are therefore in agreement with Mr. Sanghvi that the Impugned Order passed in the given facts is contrary to the p....