TMI Blog2021 (11) TMI 714X X X X Extracts X X X X X X X X Extracts X X X X ..... hing time to petitioner. An assessment order being the commencement point of various rights and or obligations that accrue to assessees, it is necessary that a reasonable time is granted to the assessees to file their objections. In this context, it is relevant to bear in mind that the Hon'ble Supreme Court had extended all periods of limitation till 02.10.2021 taking into consideration, the s ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... titioner under Section 74 (1) of the CGST/SGST Act, 2017 which is stated to have been served on the petitioner on 12.08.2021. However, thereafter, the explanation as sought for was not filed by the petitioner. 2. It is the case of the petitioner that due to Covid related issues, petitioner was laid up and even hospitalized as a result of which, he could not file his objections to the notice ser ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ing into consideration, the specific issues relating to Covid. In such circumstances, it cannot be said that petitioner had been granted sufficient opportunity to reply to the notice. The claim of the petitioner that he had time till 02.10.2021 as directed by the Hon'ble Supreme Court, cannot also be lost sight of. In any event, having regard to the contentions raised, I am of the view that ..... X X X X Extracts X X X X X X X X Extracts X X X X
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