ORDER

This case was heard along with a batch of 250 Writ Petitions and as one of the 53 Writ Petitions which were finally heard on the larger issue regarding the challenge to the proceedings under Section 74 of the respective GST Enactments.

2. In this Writ Petition, the Petitioner has challenged the Impugned Order dated 03.02.2025 for the Tax Period 2017-2018.

3. The Petitioner was earlier issued with an Intimation in Form GST DRC-01A dated 20.09.2023 for the Tax Period 2017-2018, to which, the Petitioner had replied on 29.10.2023 stating that the proposal in the said Intimation in Form GST DRC-01A dated 20.09.2023 was time barred in terms of limitation under Section 73 of the respective GST Enactments.

4. The disputed had arisen on account of a mismatch between the amount in GSTR-2A and the amount claimed by the Petitioner as Input Tax Credit in GSTR-3B.

5. The facts reveal that the Petitioner had claimed excess Input Tax Credit in GSTR-3B for discharging the tax liability during the Tax Period 2017-2018.

6. Since the Petitioner’s reply was not found acceptable, a Show Cause Notice in Form GST DRC-01 dated 06.12.2023 was issued to the Petitioner. At this ti