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ANJANI SEEDS AND FERTILIZERS DEPO v. THE STATE OF GUJARAT & ORS. – Gujarat High Court

High Court, Gujarat
Bhargav D. Karia, Justice & Pranav Trivedi, Justice

ANJANI SEEDS AND FERTILIZERS DEPO
v.
THE STATE OF GUJARAT & ORS.

R/SPECIAL CIVIL APPLICATION No. 11080 of 2025 dated 16.10.2025

Law : GST
Act Name : Central Goods & Service Tax Act, 2017
Relevant Section : Section 17, 73 & 107
Decision : Matter remanded back

Penalty – Demand – Discrepancy between Form GSTR-3B and GSTR-2A – Credit blocked under Section 17(5) – Petitioner submitted detailed reply explaining difference due to credit notes reported as output tax liability – Adjudicating authority dropped blocked credit issue but confirmed demand based on discrepancy without considering petitioner explanation – Appeal rejected as time-barred – Delay of 12 days – Petitioner argued limitation to be counted from physical service of order, appeal delay condonable – Held: Orders quashed and set aside – Matter remanded for fresh adjudication considering petitioner explanation and providing opportunity of hearing to be completed within 12 weeks.

Represented By:

Counsel for the Petitioner: Uchit N Seth

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