9911796707
TMI Blog2024 (7) TMI 1383X X X X Extracts X X X X X X X X Extracts X X X X ..... order dated 27.04.2024 (hereafter the impugned order) and the consequent demand notices issued by respondent no.2. 3. The impugned order was passed under Section 73 of the Central Goods and Services Tax Act, 2017 (hereafter the CGST Act) in respect of the tax period from April, 2018 to March, 2019. 4. The impugned order was passed pursuant to the Show Cause Notice dated 30.01.2024 (hereafter the SCN) based on a Special Audit Report. The SCN is founded on the reasoning that that the petitioner's response to the Special Audit Report has been found to be incomplete/ inconclusive. Accordingly, respondent no.2 proposed to raise a demand of Rs.163,91,65,902/- on account of Integrated Tax, Central Tax and State Tax. In addition, respondent no.2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ltiple assumptions and presumptions. The auditor has recorded its finds without any application of mind to the extent that a Company having multiple GST registrations can operate a single bank account for its PAN India operations. It has been submitted by the Company that the Company maintains a single bank account for its PAN India operations. Further, there is no requirement under GST laws to maintain separate bank accounts for separate GST registrations. Since the Company has GST registrations in multiple states, all receipts from sale of tickets in different states are received in the same bank account. The special auditor has, without any application of mind and based on irrelevant assumptions has compared the revenue for the Sta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... because only the bifurcation of total and Tamil Nadu turnover is germane. ... The total tax imposed under this head is about Rs.14.56 crores and the patent errors justify interference with the assessment order even without examining the order in respect of other defects for which liability was imposed. Therefore, the impugned assessment order cannot be sustained." The Company would wish to submit that all proceeds are received by the Company through banking channels and all GST liability is duly discharged on the sale of tickets made from Delhi location and other GST registrations. Accordingly, the demand raised in the captioned point does not hold good. Basis the above, Company would request your good self to drop the observation. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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