TMI Blog2024 (7) TMI 163X X X X Extracts X X X X X X X X Extracts X X X X ..... - assessment periods are challenged primarily on the ground of breach of principles of natural justice - mismatch between the GSTR 3B returns filed by the petitioner and the auto-populated GSTR 2A returns - HELD THAT:- The documents on record disclose that the liability pertains to alleged mismatch between the GSTR 3B returns of the petitioner and the auto-populated GSTR 2A returns. In recognitio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... - HONOURABLE MR. JUSTICE SENTHILKUMAR RAMAMOORTHY For Petitioner : Mr. K.A. Parthasarathy Mr. N. Chandirasekar for Mr. N. Prasad For Respondents : Mr.V.Prashanth Kiran, Govt. Adv.(T) for R1 COMMON ORDER Assessment orders in respect of two distinct assessment periods are challenged primarily on the ground of breach of principles of natural justice. 2. The petitioner is a partnership firm engaged ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... een the above-mentioned returns. Learned counsel contends that such Circular envisages the conduct of an enquiry by the assessing officer and that the taxpayer is entitled to submit a certificate either from the supplier or from the Chartered Accountant depending on the quantum of discrepancy. Learned counsel further submits that even a detailed show cause notice was not issued in these matters an ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... B returns of the petitioner and the auto-populated GSTR 2A returns. In recognition of difficulties faced in this regard, Circular No. 183 was issued. The petitioner has also placed on record a certificate from the Chartered Accountant with regard to the reason for disparity between the above mentioned returns. Although the petitioner did not respond to the notices and participate in the assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X
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