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TMI Blog2024 (7) TMI 170X X X X Extracts X X X X X X X X Extracts X X X X ..... o contest the tax demand on merits - mismatch between the petitioner's GSTR 1 statement and the GSTR-3B returns - HELD THAT:- The tax proposal relates to a mismatch between the petitioner's GSTR- 3B returns and the GSTR-1 statement. The petitioner asserts that this was on account of an erroneous double reporting of turnover both by the petitioner and its sister concern M/s.Proactive System ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... match between the petitioner's GSTR 1 statement and the GSTR-3B returns. The petitioner replied thereto on 19.04.2023. By asserting that the said show cause notice was served on the petitioner through email, whereas the subsequent reminders and the impugned order were merely uploaded on the portal, the present writ petition was filed. 3. Learned counsel for the petitioner submits that the show ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... M/s.Proactive Systems. In such situation, she submits that the recipient of goods from these two entities would have availed of input tax credit (ITC). In the absence of any credit notes being issued by he petitioner, she submits that the tax authority was constrained to confirm the tax proposal. 5. On examining the impugned order, it is evident that the tax proposal relates to a mismatch between ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed tax demand was received, the second respondent is directed to provide a reasonable opportunity to the petitioner, including a personal hearing, and thereafter issue a fresh order within three months from the date of receipt of 0 the petitioner's reply. 7. W.P.No.15810 of 2024 is disposed of on the above terms without any order as to costs. Consequently, the connected miscellaneous petitions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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