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2025 (1) TMI 1361

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..... s. 421 and 422 of 2024 - -
GST
Rejection of appeal on the ground of time limitation - mismatch between GSTR -3B and GSTR-2A - petitioner is ready and willing to pay 25% of the disputed tax and that he may be granted one final opportunity before the adjudicating authority to put forth their objections to the proposal - HELD THAT:- The impugned order dated 29.04.2024 is set aside - The petitio .....

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..... hat there was mismatch between GSTR -3B and GSTR-2A. 2.1. Pursuant thereto, a notice in DRC-01A was issued to the petitioner on 09.07.2022, followed by a show cause notice in DRC 01 on 24.11.2023 and reminder on 12.04.2024. Further, personal hearing was offered on 16.04.2024. The petitioner filed its reply on 23.12.2023. However, the same was rejected on the premise that the taxpayer has failed t .....

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..... assing of the impugned order, the petitioner had filed an appeal along with 10% pre-deposit and his only request is that the same may be adjusted towards 25% of the disputed tax, to which the learned Government Advocate appearing for the respondent does not have any serious objection, while seeking liberty to verify the correctness of the statement relating to remittance made by the petitioner. 4 .....

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..... sum within a period of three weeks from such intimation. d) The entire exercise of verification of payment, if any, intimation of the balance sums, if any, to be paid for compliance with the direction of payment of 25% of the disputed taxes, after deducting the sums already paid and payment by the petitioner of the balance amount, if any, on intimation in compliance of the above direction, shal .....

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..... ting documents/material. If any such objections are filed, the same shall be considered by the respondent and orders shall be passed in accordance with law after affording a reasonable opportunity of hearing to the petitioner. It is made clear that if the above conditions viz., 25% of disputed taxes is not complied or objections are not filed within the stipulated period, four weeks respectively f .....

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