TMI Blog2024 (4) TMI 766X X X X Extracts X X X X X X X X Extracts X X X X ..... the tax demand - mismatch between the GSTR 3B and GSTR 1 returns - HELD THAT:- From the impugned order, it is evident that such order was issued without hearing the petitioner. No doubt, the petitioner was provided an opportunity but failed to avail of such opportunity. It is also clear that the tax liability pertains to three issues, namely, output mismatch between GSTR 3B and 1, input mismatch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... onal hearing, and thereafter issue a fresh order within two months from the date of receipt of the petitioner's reply. The writ petition is disposed of. Consequently, connected miscellaneous petitions are closed. - Honourable Mr. Justice Senthilkumar Ramamoorthy For the Petitioner : Mr.T.Pramod Kumar Chopda, Sr. Counsel for Ms.P.Aruna Chopda For the R1 : Mr.V.Prashanth Kiran, Government Advo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... iscrepancies by referring to the impugned order, he points out that the extent of discrepancy was only Rs. 5,210/- each towards SGST and CGST as regards outward supply and only about Rs. 18,143/- each towards SGST and CGST as regards ITC. He also points out that a sum of Rs. 2,25,073/- was debited from the electronic ledger of the petitioner before the writ petition was filed and that further amou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the tax liability pertains to three issues, namely, output mismatch between GSTR 3B and 1, input mismatch between GSTR 3B and 2A and e-way bill verification. As contended by learned senior counsel, on the first two issues, the extent of discrepancy is not substantial. The summary of the show cause notice does not appear to deal with the issue relating to e-way bill verification. It is also n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of the petitioner's reply. Since the impugned assessment order dated 09.11.2023 has been set aside, the consequential attachment order dated 16.03.2024 is also set aside and the attachment is raised. For the avoidance of doubt, it is made clear that amounts appropriated pursuant to the above orders shall abide by the outcome of the remanded proceedings. 7. The writ petition is disposed of on t ..... X X X X Extracts X X X X X X X X Extracts X X X X
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