9911796707
TMI Blog2023 (12) TMI 356X X X X Extracts X X X X X X X X Extracts X X X X ..... ioner contains only the summary - annexure to DRC-01 was not furnished to the petitioner to enable them to respond - opportunity granted was not real but illusory - HELD THAT:- This Court finds merit in the submission of the learned counsel for the petitioner inasmuch as the impugned order suffers from more than one infirmity. Firstly, DRC-01 is not supported by the Annexure to show cause notice a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... DER This writ petition is filed challenging the impugned order dated 19.03.2020 on the premise that it has been made within 2 days of issuance of Form GST DRC- 01 which is the summary of the show cause notice. 2. It is submitted by the learned counsel for the petitioner that Form GST DRC-01 served on the petitioner contains only the summary, however, the annexure to DRC-01 was not furnished to the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... mitted by the learned counsel for the Respondent that DRC-07 dated 17.03.2020 was preceded by another notice dated 27.11.2018 followed by a reminder notice on 29.11.2018 and therefore the submission of the petitioner that they have not been provided with adequate opportunity is contrary to the facts. Thus, there are two orders of assessment one dated 17.03.2020 and the other dated 19.03.2020, in r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... inasmuch as the impugned order suffers from more than one infirmity. Firstly, DRC-01 is not supported by the Annexure to show cause notice and thus the petitioner was not provided with the particulars necessary to respond. Secondly, the assessment order is made on 17.03.2020. One fails to understand as to how the show cause notice as well as the assessment order has been made on the very same day. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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