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TMI Blog2024 (12) TMI 140X X X X Extracts X X X X X X X X Extracts X X X X ..... N - calculation of period of limitation from the date when the original assessment order was passed - HELD THAT:- After assessment order has been made, Section 161 of the GST Act provides for an application to be made for rectification. Such rectification can be disposed either in favour of the assessee or against him. If any rectification is made as prayed for, the same would get merged into the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... date on which the rectification had been dismissed. Petition disposed off. - Honourable Mr. Justice K. Kumaresh Babu For the Petitioner : Mr. B. Vijay Karthikeyan For the Respondent : Mr. J. K. Jayaselan Government Advocate COMMON ORDER Heard Mr.B.Vijay Karthikeyan, learned counsel for the petitioner and Mr.J.K.Jayaselan, learned Government Advocate for the respondent. 2. The Writ Petitions hav ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , the impugned order has been passed. The rectification application has been dismissed holding that the grounds raised in the rectification petition are all in the nature of challenging the order of assessment. Further, the challenge in the Writ Petition apart from the vagueness of the show cause notice which had already been held, since had been acted upon by the petitioner, the said claim could ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... im. If any rectification is made as prayed for, the same would get merged into the original order. Just because the rectification application has been rejected, the period of limitation to challenge the original assessment order cannot be said to begin from the date on which the original order was passed, it would only count from the date on which the order of rectification has been passed. 6. In ..... X X X X Extracts X X X X X X X X Extracts X X X X
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