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2024 (6) TMI 363

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..... - This Court is of the view that there is no merit in the present Writ Petition. If at all, the petitioner ought to have filed statutory appeal under Section 107 of the respective GST enactment before the Appellate Commissioner. The time for filing appeal has already expired as the impugned order is dated 20.04.2023 and the Writ Petition has been filed exactly one year and nine days later on 29.04 .....

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..... reflected in Form GSTR-07 under Rule 61 of the TNGST Rules, 2017 read with Section 15 of the TNGST Act, 2017. Later, the department realised that the petitioner had not paid tax and had recovered the amount from the petitioner and acknowledged the same in DRC 03 dated 08.08.2022. 2. It is noticed that the impugned order was passed on 20.04.2023, however, the petitioner has failed to file an appeal .....

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..... ory appeal under Section 107 of the respective GST enactment before the Appellate Commissioner. The time for filing appeal has already expired as the impugned order is dated 20.04.2023 and the Writ Petition has been filed exactly one year and nine days later on 29.04.2024. 5. Considering the fact that the amount has already been recovered from the petitioner on 08.08.2022 as it is evident from For .....

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