2026 (9) TMI 1353

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....ated 03.12.2025 passed under Section 73 of the CGST/RGST Act, 2017, whereby demand of GST amounting to Rs. 2,58,55,445/-, interest amounting to Rs. 1,69,26,223/- and penalty of Rs. 26,31,862/- has been raised against the petitioner, along with the consequential order dated 24.04.2026, rejecting the petitioner's application for rectification. 2. Brief facts of the case are that the petitioner's books of accounts, records and returns for the Financial Year 2021-22 were audited by the respondent-department, pursuant to which Form GST ADT-02 dated 01.09.2025 was issued. Thereafter, Form GST DRC-01 dated 18.09.2025 was issued proposing a tax demand of Rs. 2,58,55,445/-, along with applicable interest and penalty. Pursuant thereto, an orde....

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.... the ledger to the extent of approximately Rs. 4.52 crores. The rectification application was thereafter rejected vide order dated 24.04.2026 on the ground that no error apparent on the face of the record was found, without granting the petitioner the requested opportunity of personal hearing. The petitioner has consequently approached this Court challenging the order dated 03.12.2025 as well as the rectification rejection order dated 24.04.2026. The petitioner states that the statutory appeal against the order dated 03.12.2025 could not be instituted within the prescribed period as the petitioner claims to have acquired knowledge of the order only subsequently, and therefore seeks condonation of the delay in filing the appeal on the afores....