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TMI Blog2025 (5) TMI 1355X X X X Extracts X X X X X X X X Extracts X X X X ..... hali Gupta, Panel Counsel (Civil), GNCTD. ORDER PER 1. This hearing has been done through hybrid mode. 2. The present petition has been filed by the Petitioner under Article 226 of the Constitution of India challenging the show cause notice dated 31st May, 2024 (hereinafter, 'the SCN') issued by the Department of Trade & Taxes, Government of N.C.T. of Delhi, pertaining to the Financial Year 2 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that the taxpayer had shown less liability GSTR-3B as compared to GSTR-1 or claimed excess ITC in GSTR-3B as compared to ITC accrued in GSTR-2A/2B. Accordingly, the undersigned, relied upon the accounting data available at the GST portal, issues DRC-01 under Section 73 of DGST Act, 2017 with interest and penalty for seeking the explanation along with supporting documents/clarifications as to why ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nted to the Petitioner, the Petitioner would be willing to file a reply to the SCN. 7. In view of the peculiar circumstances and bearing in mind the period that has lapsed between the assessment years and the issuance of the SCN, the impugned order is set aside. 8. Considering the fact that the Petitioner did not get a proper opportunity to be heard and no reply to the SCN has been filed by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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