9911796707
TMI Blog2024 (5) TMI 305X X X X Extracts X X X X X X X X Extracts X X X X ..... titioner were not duly considered and that the petitioner was not provided a reasonable opportunity - violation of principles of natural justice - HELD THAT:- The entire tax liability is on account of the disparity between the petitioner s GSTR 3B return and the auto-populated of GSTR 2A return. In accordance with Circular No.183, the petitioner obtained a certificate from the supplier albeit bela ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ded a reasonable opportunity. 2. The petitioner is a dealer in polyester yarn and had filed returns pertaining to the assessment period 2017-2018. In relation thereto, upon noticing the disparity between the petitioner's GSTR 3B returns and the auto populated GSTR 2A returns, a show cause notice was issued to the petitioner on 23.08.2023. The petitioner replied thereto on 27.10.2023 by enclos ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sued on 20.02.2024, which is subsequent to the impugned order. If such certificate had been obtained and submitted to the respondent, she submits that the respondent would have had relevant documents to effectively adjudicate the matter. 5. After pointing out that the supplier's certificate explains the disparity except to the extent of Rs. 91,513/-, on instructions, learned counsel submits t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 1,00,000/- towards the disputed tax demand. Subject to receipt thereof, the respondent is directed to provide a reasonable opportunity to the petitioner, including a personal hearing, and thereafter issue a fresh order within two months from the date of receipt of the above mentioned sum of Rs. 1,00,000/-. Consequently, connected miscellaneous petitions are closed. No costs. X X X X Extracts X X X X X X X X Extracts X X X X
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