The opening words β€˜any person’ in Section 122(1A) of the CGST Act, 2017, are to be understood in the context of a β€˜taxable person’, since sub-section (1) itself applies to a taxable person – Amit Manilal Haria and Ors. Vs. Joint Commissioner, CGST & Central Excise and Anr. – Bombay High Court

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