TMI Blog2024 (6) TMI 1085X X X X Extracts X X X X X X X X Extracts X X X X ..... otice on account of personal difficulties - mismatch between the GSTR 1 statement and the GSTR 3B return - HELD THAT:- It is evident that the confirmed tax proposal relates entirely to a mismatch between the GSTR 1 statement and the GSTR 3B return. Such proposal was confirmed because the petitioner did not reply to the show cause notice or attend personal hearing. In these circumstances, albeit by ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... personal difficulties. Since the petitioner was unable to defend the tax proposal on merits, the present writ petition was filed. 2. Apart from the denial of reasonable opportunity of hearing, learned counsel for the petitioner submits that statutory rules were violated by initiating action entirely on the basis of a mismatch between the GSTR 1 statement and GSTR 3B returns. If provided an opport ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... GSTR 1 statement and the GSTR 3B return. Such proposal was confirmed because the petitioner did not reply to the show cause notice or attend personal hearing. In these circumstances, albeit by putting the petitioner on terms, it is just and necessary that the petitioner be provided an opportunity to contest the tax demand on merits. 5. Solely for reasons set out above, the impugned order dated 17 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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