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2024 (6) TMI 341

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..... TR 3B and GSTR 1 by pointing out that the discrepancy is on account of not reckoning the total value of credit notes. The petitioner has placed on record the GSTR 1 statement and the annual return in GSTR 9. Both these documents reflect the total value of credit notices as Rs. 68,91,320/-. As regards the variation in input tax credit between the GSTR 3B returns of the petitioner and the auto-populated GSTR 2A, the petitioner has explained the difference by pointing out that one of the suppliers, S.M.Network, did not reflect invoices for supplies made by such supplier. In spite of the petitioner's GSTR 1 statement and the annual return in GSTR 9 being available, no reasons are specified as to why the petitioner's explanation was reje .....

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..... ment and the annual return in GSTR 9, learned counsel pointed out that the total value of credit notes of Rs. 68,91,320/- is mentioned therein. As regards the variation between the GSTR 2A and GSTR 3B, learned counsel pointed out that such difference was on account of one supplier, S.M.Network, not reflecting the invoices in returns filed by such supplier. Learned counsel also pointed out that the annual return and the relevant invoices were enclosed with the reply to the show cause notice. By turning to the impugned order, learned counsel points out that the petitioner's explanation and the relevant documents were not taken into consideration. 3. Mr.V.Prashanth Kiran, learned Government Advocate, accepts notice for the respondent. By i .....

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..... take further action, one reminder notice was sent to them with personal hearing but they failed to pay the tax. Hence an Assessment order issued under Section 73 of CGST ACT 2017 with tax, interest and penalty as due for payment. The above operative portion is bereft of reasons. In spite of the petitioner's GSTR 1 statement and the annual return in GSTR 9 being available, no reasons are specified as to why the petitioner's explanation was rejected. Even with regard to the discrepancy between the petitioner's GSTR 3B returns and the auto-populated GSTR 2A, in spite of the petitioner enclosing the relevant invoices to explain the discrepancy, the impugned order does not discuss the explanation and record reasons for rejecting the .....

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