TMI Blog2024 (5) TMI 179X X X X Extracts X X X X X X X X Extracts X X X X ..... the tax proposal in respect of the said discrepancy was confirmed by an earlier order and that the petitioner intends to challenge such order by separate proceedings - under declaration of ineligible ITC and invalid ITC under Section 16(4) - HELD THAT:- On examining earlier order and the impugned show cause notice, it is clear that they pertain to assessment period 2018-19. The first issue in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ised therein, i.e. difference in output tax liability between GSTR-1 and GSTR-3B returns, was the subject of order dated 23.12.2023. 2. The petitioner states that an order dated 23.12.2023 was issued in respect of difference in output tax liability as between the petitioner's GSTR-1 and GSTR-3B returns. In these circumstances, the present writ petition was filed because a show cause notice dat ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 5. On examining earlier order dated 23.12.2023 and the impugned show cause notice, it is clear that they pertain to assessment period 2018-19. The first issue in the impugned show cause notice is the same issue determined under order dated 23.12.2023. Undoubtedly, it is not open to the respondent to reopen the same issue after issuing the order dated 23.12.2023. 6. In these circumstances, W.P.No. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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