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Today’s newsletter analytically summarizes the top GST stories reported at taxmann.com .

HC set aside order as assessee was asked to appear for personal hearing within 2 hours of receiving SCN

Brakes India (P.) Ltd. v. Assistant Commissioner (ST) - [2024] 158 taxmann.com 219 (Madras)

The petitioner was a registered person under the current GST regime. The department issued a show cause notice (SCN) proposing to block the petitioner's Input Tax Credit (ITC) under Rule 86-A in respect of purchases made from a particular supplier. It filed a writ petition against the order and contended that a reasonable opportunity was not provided to submit relevant documents and explain the facts and circumstances.

The Honorable High Court noted that the SCN was served on petitioner by e-mail and the personal hearing was fixed on the same date at 2.00 pm, i.e. within two hours from the time of receipt of the e-mail. The Court further noted that the petitioner had been directed to reverse an ITC of a substantial value and such action had been taken pursuant to the SCN, which the petitioner asserts was received on the date of hearing.

The Court observed that a reasonable opportunity was not provided to the petitioner to submit the necessary documents and provide an explanation to the department. Therefore, the Court held that the impugned order was to be set aside and the matter was to be remanded for reconsideration.

ITC reversed late at night during search proceedings was not voluntary and to be returned to taxpayer: HC

Santosh Kumar Gupta v. Commissioner, Delhi Goods & Services Tax Act - [2024] 158 taxmann.com 226 (Delhi)

The petitioner was engaged in the business of manufacturing and trading of electrical goods. The department conducted a search at his business premises and the petitioner was compelled to reverse the ITC amounting to Rs. 22,14,226. He filed a writ petition seeking a refund of ITC as he was compelled to reverse ITC.

The Honorable High Court noted that the petitioner had filed FORM GST DRC-03 but there was no acknowledgement of receipt by the Department by issuing FORM GST DRC-04. Also, the petitioner had filed a writ petition after one month from a recording of the statement and the same was being retracted.

The Court also noted that the petitioner may have reversed ITC in intimidating circumstances and he would not reverse ITC in normal course late at night. Therefore, the contention of the department that the reversal was voluntary was not acceptable and the Court directed the department to restore ITC.

That’s it from us for today! Stay Tuned for more updates from Taxmann.com .

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