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TMI Blog2025 (2) TMI 787X X X X Extracts X X X X X X X X Extracts X X X X ..... rant liberty to the petitioner to file an appeal against all the other issues pertaining to the impugned assessment order dated 30.08.2024. As rightly contended by the petitioner, the respondent found "Security Wages" and disputed the same, only upon production of documents by the petitioner. Prior to the furnishing of documents, no such issue was raised either vide show cause notice or in any other manner. In the show cause notice also, the respondent had stated only with regard to the "Administration Expenses". Conclusion - This Court is of the considered view that it is a fit case to interfere on the aspect of non-providing of any opportunity of personal hearing to the petitioner. Therefore, this Court is inclined to set aside the impu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd Rs. 26,12,541/- as SGST. 4. Further, he would submit that prior to the passing of impugned order, the aforesaid issue, viz., "Security Wages", was not raised by the respondents either in the show cause notice dated 29.05.2024 or in any manner, due to which, no opportunity was provided to the petitioner to explain their case on the said aspect. Hence, he would contend that in non-application of mind, the 1st respondent had passed the impugned order, which travels beyond the scope of show cause notice issued by the 2nd respondent and requests this Court to set aside the said impugned order to the extent of security wages alone. That apart, he seeks liberty of this Court to file an appeal with regard to all other aspects. 5. In reply, the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... relief only with regard to the "security wages" and requested this Court to grant liberty to the petitioner to file an appeal against all the other issues pertaining to the impugned assessment order dated 30.08.2024. 10. As rightly contended by the petitioner, the respondent found "Security Wages" and disputed the same, only upon production of documents by the petitioner. Prior to the furnishing of documents, no such issue was raised either vide show cause notice or in any other manner. In the show cause notice also, the respondent had stated only with regard to the "Administration Expenses". 11. Normally, if any discrepancy is traced out subsequent to the furnishing of documents, the respondents are supposed to have pointed out the same ..... X X X X Extracts X X X X X X X X Extracts X X X X
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