2023 (11) TMI 1270

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..... lenging the impugned show cause notice dated 29.09.2023 (Ex.P1), learned counsel for the petitioner submits that a notice (Ex.P9) dated 04.09.2023 calling objections on the discrepancy was served on 14.09.2023, and before the petitioner could file the reply, within the statutory period of 15 days the order was passed on 29.09.2023. He has referred to Ex.P12 in which "the notice issued date is 14.0 .....

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..... to be a registered person on the date of service of the first notice. He has placed reliance in the case of Tvl. Raja Stores v. Assistant Commissioner (ST), of the Madras High Court that in such a circumstance, the audit could not be initiated. 5. He further submits that in any case the audit should have been completed within 3 months from the date of its initiation but that period expired and th .....

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..... istration , such audit could be legally made. 8. With respect to the submission of time of completion of audit, learned Government Pleader submits that in view of Section 65, itself it cannot be said that the audit was not completed within statutory period. 9. At present, what we find, prima facie, is that though the notice Ex.P9 is dated 04.09.2023 and the period mentioned there under for the p .....

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