TMI Blog2020 (1) TMI 634X X X X Extracts X X X X X X X X Extracts X X X X ..... of the show cause notice, reply and order of assessment make it apparent that the discrepancies noted by the authorities as well as the objections raised refer to several factual matters and it is only upon an appreciation of the same can the disputes be resolved - while the petitioner can certainly challenge the order as being incorrect in its appreciation of transactions in question, there is n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x) ORDER Heard Mr.M.Sunil Kumar, learned counsel for the petitioner and Mr.V.Haribabu, learned Additional Government Pleader (Tax) for the respondent. 2. Two orders of assessment for the periods 2012-2013 and 2013-2014, both dated 06.07.2015, are impugned before me. There was a surprise inspection in the premises of the petitioner on 16.06.2014, pursuan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the CFS. 4. The petitioner argues that the additions in regard to the transactions of import are liable to be deleted, since the consignment was substantially delayed, and upon arrival, detained in the CFS. 5. I do not propose to delve into these explanations, being pure questions of fact. A perusal of the show cause notice, reply and order of assessment make it appa ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... m stay for some time, in the interests of justice, the petitioner is granted liberty to file an appeal before the 1st appellate authority, if it so desires and such appeal, if presented with pre-deposit and in accordance with law within a period of two weeks from today, shall be received by the registry of the appellate authority without reference to limitation and taken up for hearing and adjudic ..... X X X X Extracts X X X X X X X X Extracts X X X X
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