TMI Blog2024 (7) TMI 256X X X X Extracts X X X X X X X X Extracts X X X X ..... ot have a reasonable opportunity to contest the tax demand on merits - petitioner was unaware of proceedings culminating in the impugned assessment order - communications were uploaded on the GST portal and not communicated to the petitioner through any other mode - HELD THAT:- On perusal of the show cause notice, it appears that the tax proposal relates to a mismatch between the petitioner's ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sposed off. - Honourable Mr. Justice Senthilkumar Ramamoorthy For the Petitioner : Mr. P. Rajkumar For the R1 : Mr. V. Prashanth Kiran, Govt. Adv. (T) ORDER An order in original dated 30.12.2023 is assailed on the ground that the petitioner did not have a reasonable opportunity to contest the tax demand on merits. Pursuant to show cause notice dated 29.09.2023, the impugned order was issued on 3 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... se notice dated 29.09.2023 and by offering a personal hearing to the petitioner. 4. On perusal of the show cause notice, it appears that the tax proposal relates to a mismatch between the petitioner's GSTR 3B return and the GSTR 1 return as also between the petitioner's GSTR 3B return and the auto-populated GSTR 2A. Such proposal was confirmed without the petitioner being heard. The petiti ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ity to the petitioner, including a personal hearing, and thereafter issue a fresh order within a period of three months from the date of receipt of the petitioner's reply. On account of the assessment order being set aside, the bank attachment is raised. 6. The writ petition is disposed of on the above terms without any order as to costs. Consequently, connected miscellaneous petitions are clo ..... X X X X Extracts X X X X X X X X Extracts X X X X
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