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2025 (7) TMI 1393 - HC - GSTChallenge to assessment order - time limitation - expiry of the limitation period for filing an appeal - HELD THAT - The petitioner was issued notices for personal hearing. However the petitioner failed to reply to the same and thus suffered the impugned assessment order dated 24.04.2024. Long after the expiry of the limitation period for filing an appeal the petitioner has now approached this Court to quash the said order. It is noticed that the petitioner did not participate in the proceedings before the respondent prior to the passing of the impugned order. Under similar circumstances this Court come to rescue the persons like the petitioner subject to the persons deposit 25% of the disputed tax confirmed vide assessment orders in cash through the electronic cash ledger. There are no reason to deviate from the consistent practice followed by this Court. The writ petition is disposed of by quashing the impugned order subject to the petitioner depositing 25% of the disputed tax confirmed vide impugned order within a period of 30 days from the date of receipt of a copy of this order. The Madras High Court, through Justice C. Saravanan, addressed a writ petition challenging the impugned assessment order dated 24.04.2024 for the tax period 2020-2021, preceded by notices in Forms GST ASMT 10, GST DRC 01A, and GST DRC 01. The petitioner failed to respond to personal hearing notices and did not participate in proceedings before the respondent, resulting in the assessment order. Despite the delay beyond the limitation period for appeal, the Court, consistent with its prior practice, allowed relief subject to the petitioner depositing "25% of the disputed tax confirmed vide impugned order" via electronic cash ledger within 30 days and filing a reply to the show cause notice dated 10.11.2022, treating the impugned order as an addendum. Failure to comply would result in dismissal of the writ petition and resumption of proceedings. The petition was disposed of accordingly, with no order as to costs.
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