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2023 (9) TMI 1660

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..... uliar facts of the case and the position in law, it is intended that the Department hears the petitioner on these issues and takes an appropriate call on the contentions as raised by the petitioner after hearing the petitioner and by passing an appropriate reasoned order, on the contentions as urged by the petitioner and in the light of the observations made by the appellate authority. In fact, su .....

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..... s are lying with the Department since 2012-2013 as per the following details as appearing at page 29 of the petition:- "(Amount in Rs.) Particulars Date of Deposit Amount Deposited Service Tax Amount 22.10.2012 22.03.2013 3,39,21,088 33,00,60,283 Interest Amount 03.06.2013 19,80,02,704 Total deposits made 'under protest' 56,19,84,075 3. The petitioner has raised a contentio .....

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..... s and takes an appropriate call on the contentions as raised by the petitioner after hearing the petitioner and by passing an appropriate reasoned order, on the contentions as urged by the petitioner and in the light of the observations made by the appellate authority. In fact, such issues have been raised by the petitioner in its recent representation dated 24 May, 2023 as addressed to the Deputy .....

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