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TMI Blog2024 (9) TMI 502X X X X Extracts X X X X X X X X Extracts X X X X ..... opinion of the Commissioner - principles of natural justice - HELD THAT:- The language of Section 83(1) of the Central Goods and Services Tax Act, 2017, in our considered opinion is mandatorily to be followed as it visits the petitioner with penal consequences. It was, therefore, necessary that the impugned order under Section 83(1) of the Central Goods and Services Tax Act, 2017, indicate the rea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .S. JAWALKAR, JJ. Dr. Sujay Kantawala, Advocate with Mr. Anupam Dighe, Ms.Chandani Tanna, Mr. A.M. Sudame, Advocates for Petitioner Mr. N.S. Deshpande, DSGI for Respondent No.1 / Union of India Mr. S.N. Bhattad, Advocate for Respondent Nos.2 and 3 ORDER 1. At the outset, the learned counsel for petitioner seeks to delete the respondent Nos.4 to 6 from the array of respondents. The same is permitte ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s not reflect any reasons for recording such opinion. Mr. Bhattad, learned counsel for the respondents has today produced before us the copy of the original file and draws our attention to the note No.5, which according to him would be the document indicating reasons for the Commissioner forming such opinion. Though we are not legally entitled to appreciate the note, as the opinion has to be refle ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ount, belonging to the taxable person or any person specified in sub-section (1-A) of section 122, in such manner as may be prescribed. 5. The language of Section 83(1) of the Central Goods and Services Tax Act, 2017, in our considered opinion is mandatorily to be followed as it visits the petitioner with penal consequences. It was, therefore, necessary that the impugned order under Section 83(1) ..... X X X X Extracts X X X X X X X X Extracts X X X X
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