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TMI Blog2021 (2) TMI 694X X X X Extracts X X X X X X X X Extracts X X X X ..... her at the time of supply of services or on the date of the receipt of the payment, whichever is earlier - HELD THAT:- This is a disputed factual aspect which can only be resolved after a counter affidavit is filed on behalf of the respondents clearly stating the rate on which the tax was included while submitting the tender by the petitioner. The petitioner may also clarify its stand in this reg ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 22.08.2017. The respondents by the impugned letters are demanding GST @ 18% and thus have raised a demand of extra 6% to the tune of ₹ 1,26,37,192/-. 3. The submission of the learned senior counsel for the petitioner is that the charging section under the Central Goods and Services Taxes Act is Section 13 and that liability to pay taxes on the above work contract arises either at the tim ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in submitting the tenders, tax @ 12% only was included. 6. This is a disputed factual aspect which can only be resolved after a counter affidavit is filed on behalf of the respondents clearly stating the rate on which the tax was included while submitting the tender by the petitioner. The petitioner may also clarify its stand in this regard by filing an affidavit. 7. Learned ASGI may file re ..... X X X X Extracts X X X X X X X X Extracts X X X X
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