TMI Blog2024 (3) TMI 1219X X X X Extracts X X X X X X X X Extracts X X X X ..... der, it is clear that the entire tax liability is with regard to disparity between the GSTR-3B and GSTR-2B returns. The petitioner has, albeit subsequent to the issuance of such order, explained that ITC was validly availed of by submitting documents in support thereof. Undoubtedly, the petitioner was negligent in not doing so upon receipt of the intimation and show cause notice. Nonetheless, if t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the tax demand. The petitioner is a dealer of woven fabrics in cotton and readymade garments and a registered person under applicable GST enactments. Pursuant to the scrutiny of returns filed by the petitioner, a show cause notice was issued to the petitioner on 23.06.2023. The petitioner asserts that he could not reply to the show cause notice because he was awaiting particulars from his suppli ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t the petitioner was also offered a personal hearing and that principles of natural justice were adhered to. 4. On examining the show cause notice and impugned order, it is clear that the entire tax liability is with regard to disparity between the GSTR-3B and GSTR-2B returns. The petitioner has, albeit subsequent to the issuance of such order, explained that ITC was validly availed of by submitti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 9;s reply and upon being satisfied that 10% of the disputed tax demand was received, the assessing officer is directed to provide a reasonable opportunity to the petitioner, including a personal hearing, and thereafter issue a fresh assessment order within a period of two months . 6. W.P.No.7005 of 2024 is disposed of on the above terms. No costs. Consequently, W.M.P.Nos.7817 and 7820 of 2024 are ..... X X X X Extracts X X X X X X X X Extracts X X X X
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