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GST - Case Laws
Showing 301 to 320 of 16293 Records
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2025 (6) TMI 348
Challenge to procedure adopted by the Search-cum-Selection Committee in evaluating and recommending the name of the candidates for the post of Judicial Member of Goods and Services Tax Appellate Tribunal - HELD THAT:- The matter requires consideration. Hence issue notice.
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2025 (6) TMI 347
Seeking to quash the Document/Show Cause Notice along with its attachments - also seeking to quash the ex-parte order passed u/s 73 (9) of the Central Goods and Services Tax Act - HELD THAT:- While the document description on the portal is accurate, the title of the document at page no.78 incorrectly reads ‘Summary of Show Cause Notice’. The appropriate title ought to have been ‘Show Cause Notice under Section 73 of the Act’. Furthermore, a review of page no. 80 also shows that this is a summary of the Show Cause Notice, wherein the tax heads have been mentioned and the declared tax has also been mentioned.
After having perused the documents, it is clear that any Assessee, who is regularly using the GST portal clearly would know that the description on the same is stated as show cause notice and summary thereof.
It is well settled that an incorrect description of a document, by itself, does not negate its substantive content. In such situations, it is the substance of the document that must prevail over its form. The dashboard is clear, the watermark with the word ‘notice’ is clear and prominent and there can be no doubt that the document in question was a notice under Section 73 of the Act. A form DRC-01 is itself in the nature of a notice to show-cause. The said summary states that it is a Show Cause Notice under Section 73 of the Act. The reminders which were given to the Petitioner also made it clear that the earlier document was a Show Cause Notice. Under such circumstances, the plea that the document is not a Show Cause Notice is a completely frivolous and a specious plea being taken by the Petitioner, to simply justify the non-filing of its reply.
While there is no doubt that the Department ought to take adequate precaution to ensure that such errors of misdescription do not occur, what appears to be merely an inadvertent error, in the light of all the accompanying documents and circumstances cannot be the basis for seeking quashing. In view thereof, this Court is of the opinion that the impugned order does not warrant interference in exercise of writ jurisdiction. In the totality of circumstances, this Court is unable to accept the Petitioner’s contention that the disputed document is merely a summary and not a Show Cause Notice, solely on the ground of an inadvertent misdescription in the title.
Conclusion - i) The document dated 19th November, 2024, is a valid Show Cause Notice under Section 73 of the CGST Act despite the erroneous title. ii) The Petitioner was under a legal obligation to respond to the Show Cause Notice. iii) The impugned ex-parte order passed under Section 73(9) is sustainable and does not warrant interference in writ jurisdiction.
Petition disposed off.
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2025 (6) TMI 346
Challenge to order and corresponding summary orders - demand for Input Tax Credit (ITC) for the Financial Year 2017-18 despite the Show Cause Notice relating to 2018-19 - HELD THAT:- It is noticed that the impugned order dated 17th December, 2024 is a detailed order, which has set out the entire mechanism, which has been adopted by the entities therein including the Petitioner, for fraudulently passing on and availing of ITC on goods-less transactions. The submission of the Respondent is that in fact, M/s Fortune Graphics Limited, which is a supplier firm from which the Petitioner firm has availed ITC, is not even traceable and it has passed on crores worth of ITC to various entities including the Petitioner. The investigation, as per the impugned order, also reveals that Mr. Sumit Tandon, the director of M/s Fortune Graphics Limited, from whom the Petitioner is stated to have received the ITC, has admitted that no goods were supplied by Fortune Graphics. Even the e-way bill analysis reveals that the entire movement of goods itself was bogus and fake.
The question, as to whether which of the entities of the Petitioner i.e., the Delhi entity or Gurgaon entity availed of the ITC and what would be the impact of the same, would be a factual analysis, which would require a closer scrutiny. The returns filed by the various firms, which have issued the invoices and have passed on the ITC to the Petitioner as also the Petitioner’s own documents would be needed to be looked into. The said analysis would be beyond the scope of writ jurisdiction.
This Court is not inclined to entertain the present writ petition. However, the Petitioner is permitted to avail of its appellate remedies under Section 107 of the Act in accordance with law by making the requisite pre-deposit by 15th July, 2025. If such an appeal is filed along the requisite pre-deposit, the same shall be decided on merits and shall not be dismissed on the ground of being barred by limitation - Petition disposed off.
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2025 (6) TMI 345
Issuance of summary of show cause notice without passing any order under Section 73 (1) of the AGST Act, 2017 - opportunity of hearing also not provided - violation of principles of natural justice - HELD THAT:- The decision in the case of Construction Catalysers Pvt. Ltd [2024 (10) TMI 279 - GAUHATI HIGH COURT] is similar to the present case where it was held that 'This Court also cannot be unmindful of the fact that it is on account of certain technicalities and the manner in which the impugned orders were passed, this Court interfered with the impugned orders and hence set aside and quashed the same. It is also relevant to take note of that the respondent authorities were under the impression that issuance of attachment of the determination of tax which was attached to the Summary of the Show Cause Notice would constitute a valid Show Cause Notice. Under such circumstances, in the interest of justice, this Court while setting aside the impugned Orders-in-Original as detailed out in the Appendix, grants liberty to the respondent authorities to initiate de novo proceedings under Section 73, if deemed fit for the relevant financial year in question.'
The issue raised in Construction Catalysers Pvt. Ltd and the present petition is similar and therefore, the determination made in Construction Catalysers Pvt. Ltd, shall accordingly cover the present petition and as agreed to by the learned counsel for the parties, the present writ petition stands disposed of by setting aside the summary of order dated 28.02.2025 and the summary of show cause notice dated 29.11.2024 in terms of the determination and conclusion arrived at para 29 of Construction Catalysers Pvt. Ltd.
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2025 (6) TMI 344
Challenge to SCN and consequent order - vires of Notification No. 09/2023- Central Tax dated 31st March, 2023 - HELD THAT:- It is noticed that subsequent to the impugned SCN dated 23rd September, 2023 three reminders dated 13th November 2023, 22nd November, 2023 and 21st February, 2024 have also been issued. However all these reminders are uploaded on the ‘Additional Notices Tab’.
This Court in Neelgiri Machinery through its Proprietor Mr. Anil Kumar V. Commissioner Delhi Goods And Service Tax And Others [2025 (3) TMI 1308 - DELHI HIGH COURT] under similar circumstances where the SCN was uploaded vide ‘Additional Notices Tab’ had remanded the matter.
It is relevant to note that post 16th January 2024, the Department has effected changes in the portal to ensure that the Show Cause Notices become visible to parties. However, the impugned SCN and two out of three reminders in the present case are issued prior to 16th January, 2024. Under these circumstances, though one reminder has been issued post 16th January, 2024 where the same could have been visible to the Petitioner, considering the fact that the Petitioner did not get a proper opportunity to be heard and no reply to the SCN has been filed by the Petitioner, this Court is inclined to remand this matter back to the concerned Adjudicating Authority.
The Petitioner is granted time till 15th July, 2025, to file the reply to the impugned SCN. Upon filing of the reply, the Adjudicating Authority shall issue a notice for personal hearing to the Petitioner - The impugned order is set aside - petition disposed off.
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2025 (6) TMI 343
Challenge to order - petitioner was not given adequate opportunity to file a reply or attend personal hearings - violation of principles of natural justice - challenge to vires of N/N. 56/2023- Central Tax dated 28th December, 2023 - HELD THAT:- The impugned order has been passed without taking into account the stand of the Petitioner. Hence, this Court is of the opinion that the impugned order deserves to be set aside and the Petitioner shall be granted another opportunity to file a reply and to attend a personal hearing.
The Petitioner is granted time till 10th July 2025, to file the reply to SCN. Upon filing of the reply, the Adjudicating Authority shall issue a notice for personal hearing to the Petitioner - the impugned order is set aside - petition disposed off.
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2025 (6) TMI 342
Disallownace of ITC - disallowance on the ground that the return under Section 39 of CGST/WBGST Act, 2017 in Form GSTR-3B had been filed beyond the stipulated date - HELD THAT:- Prima facie upon going through the materials on record since it appears that the petitioner seeks the benefit of Section 16(5), having regard to the insertion of this Section in the GST Act and noting that the actual date of submission of the return concerning tax period August, 2019 to March, 2020 is not later than 14th January, 2021, I am of the view that the matter should be remanded back to the proper officer for the petitioner to avail the benefit of Section 16(5) of the said Act.
The matter is remanded back to the proper officer for reconsideration of the matter, having regard to the insertion of Section 16(5) in the said Act - Petition disposed off by way of remand.
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2025 (6) TMI 341
Retrospective cancellation of the GST registration - Respondent after seeking instructions, submits that the cancellation be given effect to from the date of Show Cause Notice, i.e. 04th September, 2021 - HELD THAT:- The cancellation of GST registration shall be w.e.f. 4th September 2021. Let the change be effected even in the GST portal. If the portal needs to be opened for the sake of filing of returns and any other documents, the same shall be opened within a period of ten days.
Petition disposed off.
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2025 (6) TMI 340
Maintainability of petition - availability of alternative remedy - Attachment of bank accounts - prior intimation under Form DRC-01A was not provided within the stipulated time period prescribed in terms of CGST Act and the same was issued only one day prior to the issuance of the SCN - HELD THAT:- As can be noticed from the order passed by the Supreme Court, during the pendency of this writ, the proceedings in the impugned SCN has continued, and an order under Section 74 of the CGST Act has been passed on 20th June, 2024. The Petitioner had already availed of its appellate remedy under Section 107 of the CGST Act in respect of the said order. The only issue that currently remains is in respect of the freezing of the bank account. In the opinion of this Court, after the order passed by the Supreme Court and the culmination of the proceedings in respect of the SCN, which was impugned, the order freezing the bank account would also automatically get lifted.
Since the Petitioner has already now availed of the appellate remedy assailing the final order passed in the SCN proceeding, the order dated 28th May, 2024, freezing the bank account of the Petitioner shall stand lifted.
Petition disposed off.
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2025 (6) TMI 339
Seeking release of detained goods - petitioner submits that the subject conveyance and subject goods may be released in favour of the petitioner by imposing terms and conditions and that the petitioner would abide and comply with the same, in accordance with law - HELD THAT:- Though several contentions have been urged by both sides in support of their respective claims, having regard to the specific submission made by the petitioner and in the facts and circumstances of the instant case and the judgment of the Hon’ble Division Bench in M/s. Karthik Agencies [2024 (11) TMI 521 - KARNATAKA HIGH COURT], it is deemed just and appropriate to dispose of this petition by directing the respondents to release the subject conveyance and goods in favour of the petitioner by imposing certain conditions.
The concerned respondents are hereby directed to release subject goods as well as subject conveyance bearing No.KA-16-D-2418 in favour of the petitioner immediately upon the petitioner depositing aforesaid 25% of the value of the goods in a sum of Rs.2,56,965/- as well as furnishing Bank Guarantee to an extent of 75% in a sum of Rs. 7,70,895/- as well as executing a personal bond in relation to the remaining demand put forth by the respondents.
Petition disposed off.
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2025 (6) TMI 338
Challenge to assessment order - said proceedings did not contain a DIN number - HELD THAT:- The question of the effect of non-inclusion of DIN number on proceedings, under the G.S.T. Act, came to be considered by the Hon’ble Supreme Court in the case of Pradeep Goyal Vs. Union of India & Ors [2022 (8) TMI 216 - SUPREME COURT]. The Hon’ble Supreme Court, after noticing the provisions of the Act and the circular issued by the Central Board of Indirect Taxes and Customs (herein referred to as “C.B.I.C.”), had held that an order, which does not contain a DIN number would be non-est and invalid.
A Division Bench of this Court in the case of M/s. Cluster Enterprises Vs. The Deputy Assistant Commissioner (ST)-2, Kadapa [2024 (7) TMI 1512 - ANDHRA PRADESH HIGH COURT], on the basis of the circular, dated 23.12.2019, bearing No.128/47/2019-GST, issued by the C.B.I.C., had held that non-mention of a DIN number would mitigate against the validity of such proceedings. Another Division Bench of this Court in the case of Sai Manikanta Electrical Contractors Vs. The Deputy Commissioner, Special Circle, Visakhapatnam [2024 (6) TMI 1158 - ANDHRA PRADESH HIGH COURT], had also held that non-mention of a DIN number would require the order to be set aside.
Conclusion - The non-mention of a DIN number in these orders, which was uploaded in the portal, requires the impugned order to be set aside.
This Writ Petition is disposed of setting aside the order of assessment, in Form GST DRC-07, dated 31.12.2024, passed by the 1st respondent, with liberty to the 1st respondent to conduct fresh assessment, after giving notice to the petitioner and assigning a DIN number to the said order.
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2025 (6) TMI 337
Restoration of the petitioner's GST registration - HELD THAT:- This petition is disposed of by directing the petitioner to approach the Competent Authority for registration of his GST number within a period of seven days from today. The Competent Authority shall restore GST number of the petitioner immediately, subject to the completion of all requisite formalities. The petitioner undertakes to file return and deposit the taxes and penalty along with the interest within a period of seven days from the restoration of GST number of the petitioner. In the event the needful is not done by the petitioner within stipulated period, suspended registration of the petitioner shall be deemed to have been restored.
Petition disposed off.
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2025 (6) TMI 336
Seeking permission to withdraw petition so as to enable the petitioner to file Appeal before the Goods and Services Tax Appellate Tribunal (GST Tribunal) as and when it comes into existence - HELD THAT:- The petition is disposed of as not pressed at this stage with a liberty to the petitioner to file Appeal as per the provisions of the Gujarat Goods and Services Tax Act, 2017 before the GST Tribunal as and when it comes into existence.
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2025 (6) TMI 335
Seeking permission to withdraw the petition with liberty to apply for GST AMNESTY Scheme, 2024 - HELD THAT:- Prayer is not opposed by the counsel for the respondents.
The instant petition is dismissed as withdrawn with liberty as prayed for.
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2025 (6) TMI 334
Cancellation of client’s registration under Central Goods and Services Tax Act, 2017 - client (petitioner) is ready and willing to pay the tax, interest, late fee, penalty and any other sum required to be paid - HELD THAT:- Reliance placed in the case of M/S. MOHANTY ENTERPRISES VERSUS THE COMMISSIONER, CT & GST, ODISHA, CUTTACK AND OTHERS [2022 (11) TMI 1521 - ORISSA HIGH COURT] where it was held that 'the delay in Petitioner’s invoking the proviso to Rule 23 of the Odisha Goods and Services Tax Rules (OGST Rules) is condoned and it is directed that subject to the Petitioner depositing all the taxes, interest, late fee, penalty etc., due and complying with other formalities, the Petitioner’s application for revocation will be considered in accordance with law.'
Petition disposed off.
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2025 (6) TMI 333
Inaction on the part of the respondents in not refunding the amount of GST collected from the petitioner in the course of the execution of the contract that was awarded to the petitioner - HELD THAT:- The writ petition as of now stands disposed of directing the State Authorities to immediately process the claim of the petitioner so far as refund of GST is concerned, after due verification of facts and also the entitlement part of the petitioner is concerned. Let an appropriate decision be taken keeping in view the earlier order of the State Government dated10.10.2018 in this regard and all subsequent orders also passed in this regard by the State. The State Authorities shall also keep in mind the contention of the petitioner that in many of the similar cases, the govt. itself has refunded the GST.
Petition disposed off.
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2025 (6) TMI 332
Rejection of petitioner's appeal on the ground that the same was barred by limitation - HELD THAT:- Admittedly, in this case the petitioner had filed an appeal challenging the order passed under Section 73(9) of the said Act. Simultaneously, with the filing of the appeal, the petitioner had also made pre-deposit of Rs. 10,900/- as is required for maintaining the appeal. As such there is no lack of bona fide on the part of the petitioner in preferring the appeal. It appears that the petitioner had also made a prayer for condonation of delay, inter alia, claiming that by reasons of lack of proper knowledge of the GST portal there had been delay in filing the appeal. There appears to be a delay of 02 days in filing the appeal.
Taking into consideration that the petitioner is a small businessman and there is no lack of bona fide on the part of the petitioner and one does not stand to gain by filing a belated appeal, in the instant case, the appellate authority ought to have appropriately considered the application for condonation of delay filed by the petitioner.
The appellate authority is directed to hear and dispose of the appeal, on merit, upon giving an opportunity of hearing to the petitioner, within a period of 8 weeks from the date of communication of this order - petition disposed off.
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2025 (6) TMI 331
Revival of the petitioner's GST registration certificate - petitioner is willing to deposit all the outstanding dues of tax including interest and penalty, if any - HELD THAT:- With the consent of learned counsel for both the parties, the present writ petition is disposed of with a direction that if the petitioner deposits entire outstanding dues of tax including interest and penalty, if any, and submits its application within one week from today, the State Tax Officer, Rishikesh, Sector-1, Goods and Services Tax shall consider the same and pass an appropriate order as per law within a period of one week from the date of production of a certified copy of this order along with the application.
Petition disposed off.
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2025 (6) TMI 330
Classification of goods - Does barter exchange apply to B2B transactions where payments are made without the involvement of bank transactions? - If Job Work is performed by an unregistered individual, does RCM apply? - does RCM cover job work provided by individuals to proprietorship concerns? - is it appropriate to mention the legal name on shipping labels and also ship the bills with discreet packaging? - In cases where insurance of goods is mandatory, can we insure the goods for a lesser value? - what are the appropriate HSN codes for scrap, melted scrap bars, melted rods and melted kacha? - Is E-way bill mandatory for purchase and sale of silver scrap, silver ornaments and silver fine? - In situations involving delivery challan for supply on approval, job work and repair when is an e-way bill required? - How can the value of products with varying purities but the same name be proved and which documents are necessary for this purpose? - Is it valid under GST to make payments to job workers in the form of materials instead of sales transactions?
Does barter exchange apply to B2B transactions where payments are made without the involvement of bank transactions? - If Job Work is performed by an unregistered individual, does RCM apply? - HELD THAT:- The barter system is covered under the scope of 'supply' and specifically exchange of silver scrap for finished ornaments will be considered a 'supply' under the GST law, despite the absence of monetary payments. In this regard, it may also be noted that Schedule I to the CGST Act, 2017, specifies activities to be treated as supply even if made without consideration.
Does RCM cover job work provided by individuals to proprietorship concerns? - HELD THAT:- In this regard, it is informed that Notification No.13/2017, CT(R) dated 28.06.2017, as amended, has clearly enumerated the situations which warrant payment of GST under reverse charge mechanism (RCM), and it can be seen that 'job-work' does not figure as one of the activities/situations listed therein. Once it becomes clear that 'job work' is not part of the said notification, the question of answering the above query does not arise.
Is it appropriate to mention the legal name on shipping labels and also ship the bills with discreet packaging? - HELD THAT:- It could be seen that the above query refers to 'discreet packaging', 'safety purposes', and whether to mention the legal name on the shipping labels, which are procedural in nature and which are not related to GST or its taxability in any manner. This apart, as the said question does not fit into any of the clauses at (a) to (g) of Section 97 (2) of the CGST Act, 2017, as enumerated above, we are of the considered opinion that no ruling is required to be pronounced in this regard.
In cases where insurance of goods is mandatory, can we insure the goods for a lesser value? - HELD THAT:- No ruling could be issued in respect of this case as well, as the question put forth by the applicant does not fall within the scope of Section 97 (2) of the CGST/TNGST Acts, 2017, and since the same is not at all related to GST in any manner, whatsoever.
What are the appropriate HSN codes for scrap, melted scrap bars, melted rods and melted kacha? - HELD THAT:- The HSN codes in respect of the specified materials are as Silver Scrap - 7112, Melted scrap Bars - 7112, Melted Silver Rods - 7106, Melted 'Kacha' (Imperfect Silver) - 7106.
Is E-way bill mandatory for purchase and sale of silver scrap, silver ornaments and silver fine? - HELD THAT:- By virtue of the provisions of provisions of Rule 138(14) of CGST Rules, 2017, goods under Chapter 71, including Silver scrap, Silver ornaments and Silver fine, as referred to by the applicant (except imitation jewellery under HSN 7117), stand exempted from E-way Bill generation at the national level, i.e., for inter-state supplies. As far as intra-state movement of such goods is concerned, we find that the Commissioner of State Tax, Tamilnadu state, in exercise of the powers conferred under clause (d) of sub-rule (14) of rule 138 of the TNGST Rules, 2017, has declared that no E-way Bill is required to be generated for intra-state movement within the state of Tamilnadu in respect of value and goods notified in the rule 138 of Tamilnadu Goods and Services Tax Rules, 2017, until further orders, by way of issue of Notification No.6 of 2018 dated 28.03.2018 issued in Rc.46/2018/Taxation/A1.
Once the option has been extended to the respective States and Union Territories, the state of Kerala has mandated the generation of E-Way Bills for intra-state movement of certain goods under Chapter 71 within their jurisdiction by way of issue of Notification No.10/2024-State Tax dated 27.12.2024 in No. SGST/6282/2023-PLC1. However, it is noticed that no such notification has been issued, or option exercised by the state of Tamilnadu so far, in this regard. Under these circumstances, the E-way Bill generation is not required for movement, whether intra-state (in Tamilnadu) or inter-state involving sale or purchase of Silver scrap, Silver ornaments and Silver fine.
In situations involving delivery challan for supply on approval, job work and repair when is an e-way bill required? - HELD THAT:- As the movement of goods in question in the instant case whether it is in relation to a supply, or it is for reasons other than supply, both get covered under rule 138 of the rules, ibid, we are of the opinion that in respect of this query also, the aforesaid discussion in para 6.7 holds good, and accordingly, generation of E-way bill is not required in situations involving supply on approval, job work and repair of silver bars and ornaments.
How can the value of products with varying purities but the same name be proved and which documents are necessary for this purpose? - HELD THAT:- No ruling could be issued in respect of this question, as it does not fall within the scope of Section 97 (2) of the CGST/TNGST Acts, 2017, and since the same is not related to GST in any manner.
Is it valid under GST to make payments to job workers in the form of materials instead of sales transactions? - HELD THAT:- No ruling could be issued in respect of this question, as it relates to the procedure for making payment of job-worker, and accounting of the value involved, which are procedural in nature, and which does not fall within the scope of Section 97 (2) of the CGST/TNGST Acts, 2017.
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2025 (6) TMI 329
Maintainability of Advance Ruling application - entitlement to avail Input Tax Credit (ITC) on goods and services procured for construction, furnishing, and infrastructure development of a commercial property that is leased out, specifically when the output service is rental of immovable property - HELD THAT:- The first proviso to Section 98(2) restricts admission of application seeking advance ruling where the questions are already pending in any proceedings in the case of an applicant under any of the provisions of the Act. Therefore, the term ‘proceedings’ assumes immense significance in the context of the instant case.
Though the term ‘proceedings’ has not been defined under the CGST/TNGST Act, 2017, it is seen to have been widely used in the Act, ibid, either as it is, in the context of the situation, or with a prefix bringing out the meaning and purpose in an unambiguous manner like ‘Recovery proceedings’, ‘Assessment proceedings’, etc.
It becomes clear that while Sections 73, 74 and 130 talk about proceedings post the issue of show cause notice, Sections 62, 63 and 64 on the other hand clearly discusses about the proceedings involving assessment, which precedes the issue of any show cause notice - an inquiry is to be seen as initiation of judicial proceedings, and the crucial aspect is that such proceedings precedes the issue of show cause notice. Accordingly, we are of the opinion that the moment an inquiry or investigation gets started, it amounts to initiation of proceedings under the provisions of the Act, irrespective of the fact whether it culminates in the issue of show cause notice or not, depending upon the facts and circumstances of the case.
The term ‘proceedings’ used in the CGST Act, 2017 is not restricted to proceedings which commence after the issue of show cause notice alone, and that the same also denotes proceedings prior to the issue of show cause notice, or proceedings which may not culminate in the issue of any show cause notice at all. Investigation is activated when there is enough predication to show that there is an alleged tax evasion and the essence of investigation is to carry out an in-depth review of the taxpayer’s records and activities to ensure that the tax due to the Government is not lost in evasion. Therefore, the commencement of investigation or inquiry is to be seen as the start of a proceeding to safeguard Government revenue.
An advance ruling is not required to be pronounced once an investigation is initiated against the applicant under the provisions of the CGST/TNGST Act involving the same issue on which the query for advance ruling has been raised. Arriving at a decision on the same issue in respect of which a show cause notice has been issued, may vitiate the adjudication proceedings involving the said notice. At this juncture, it becomes imperative to analyse as to whether the query raised in the application for advance ruling is the same on which the investigation was initiated, and whether the investigation proceedings precedes the application for advance ruling.
The initiation of proceedings by way of issue of both the summons that seeks the details/documents in relation to the issue involved in the instant case, precedes the date of filing of advance ruling application by the applicant. More specifically, the letter dated 25.05.2023 of the applicant furnishing the details of ITC availed during the period 2021-22 to 2022-23, proves the case in point.
Conclusion - The application for advance ruling filed online dated 13.09.2024 by the applicant is liable for rejection under the first proviso to Section 98(2) of the CGST / TNGST Acts, 2017, in view of the fact that ‘proceedings’ on the same issue was already pending against the applicant.
The advance ruling application is rejected.
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