The petitioner challenged orders passed in appeal confirming proceedings under Section 130 of the GST Act arising out of a survey. The factual background showed that excess stock was alleged without physical weighment and without recording findings of intent to evade tax. The petitioner argued that statutory provisions mandate assessment under Sections 73 or 74 in such cases.
The Court held that the GST Act is a complete code and where goods are not properly accounted for, proceedings must be initiated under Sections 73 or 74. Invocation of Section 130 was held to be impermissible. The impugned orders were set aside.