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TMI Blog2025 (3) TMI 362X X X X Extracts X X X X X X X X Extracts X X X X ..... lidated SCN by invoking the provisions of Section 74 of the CGST/SGST Acts for the years 2017-18 till 2021-22 - HELD THAT:- Having regard to the facts and circumstances of the case, the writ petition will stand disposed of, directing that the Competent Authority shall consider the issue for each of the years separately, if there is warrant for doing so, also taking into consideration the submissio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 17-18 till 2021-22. 2. Learned counsel appearing for the petitioner submits that, in the year 2017-18, there was failure to file returns and even if that can be seen as a case of suppression, for the subsequent years (which are also subject matter of the show cause notice), returns have been filed and tax has been remitted at the rate of 5%. It is submitted that, even if there is a mistake in the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... year will also be considered by the Adjudicating Authority, while passing orders. It is also submitted that taxes paid by the petitioner for the year 2018-19 till 2021-22 (at the rate of 5%) have been given due credit to. 4. Learned counsel appearing for the petitioner submits that, by now, the amounts payable on account of the application of an incorrect rate of tax has also been remitted by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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