TMI Blog2024 (5) TMI 303X X X X Extracts X X X X X X X X Extracts X X X X ..... 1 of 2024 - - - GST - Validity of assessment order - classification of oil coolers as heat exchangers - to be classified within HSN 8419 or 8708 - main grievance of the petitioner is that the Chartered Engineer's certificate was disregarded while concluding that oil coolers should be classified under chapter 8708 instead of 8419 - HELD THAT:- The impugned order is dated 30.12.2023 and the per ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er of oil coolers. Pursuant to an audit, the petitioner received show cause notice dated 27.09.2023. Such show cause notice was replied to by the petitioner. After a hearing, the impugned order was issued on 30.12.2023. 2. Learned counsel for the petitioner invited my attention to the impugned order and, in particular, to the issue relating to the classification of oil coolers as heat exchangers b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... submits that the petitioner was directed to pay an aggregate sum of Rs. 34,38,17,664/- towards this head of demand and that other heads of demand are insubstantial by comparison. He also points out that no finding was recorded with regard to alleged non reversal of Input Tax Credit on credit notes. 3. Mr.K.Mohanamurali, learned senior standing counsel, accepts notice for the respondents. He points ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... concluding that oil coolers should be classified under chapter 8708 instead of 8419. This contention may be raised by the petitioner in course of appellate proceedings because the overall facts and circumstances do not justify interference under Article 226 of the Constitution. 5. The impugned order is dated 30.12.2023 and the period of limitation, without condonation, expires by the end of this m ..... X X X X Extracts X X X X X X X X Extracts X X X X
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