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2022 (12) TMI 409

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..... ner herein has come up against the show cause notice. All issues raised herein are still open to agitate before the Assessing Officer. We, therefore, do not find any good ground to entertain the writ petition. The present writ petition is being disposed of with the observation that all the issues raised by the petitioner herein, especially the issue with regard to the jurisdiction of the Assess .....

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..... is to show cause notice dated 25.5.2021 issued by respondent no. 3 under Section 74 of the U.P. GST/CGST Act, 2017 for the financial year 2018 -19. Challenging the show cause notice, the learned counsel for the petitioner herein raises an issue with regard to the jurisdiction of the respondent no. 3 to proceed under Section 74 of U.P. GST/CGST Act, 2017 on the basis of a survey/SIB survey date .....

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..... he petitioner that all the issues, which may arise during the assessment proceedings under Section 74 leading to the demand and notice, have already been dealt with by the appellate authority while passing the order dated 19.7.2022. The order which runs into more than 100 pages has been placed before us to demonstrate that each and every aspect of the matter relating to the violation or the contra .....

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..... ubmits that the Revenue is contemplating to challenge the order dated 19.7.2022 passed under Section 130 of the Act, 2017 before this Court as per the instructions received as on date. Noticing the same, we find that the petitioner herein has come up against the show cause notice. All issues raised herein are still open to agitate before the Assessing Officer. We, therefore, do not find any goo .....

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..... se, such a reply is given within a period of two weeks from today, the Assessing Officer shall be under obligation to deal with all the contentions of the petitioner made in the reply submitted on 5.8.2022 and the supplementary reply, if any, filed under the order of this Court and decide the same strictly in accordance with law. It goes without saying that the issue pertaining to jurisdiction of .....

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