Assessment — The statutory provisions are clear with regard to the time frame within which the assessee has to file his return and pay tax based on the said returns if he wants the assessment done on best judgment basis to be cancelled. The assessee failed to file the returns within the time available under the SGST Act. Thus, the statutory prescription of 30 days from the date of receipt of the assessment order passed under sub section (1) of Section 62 has to be strictly construed against an assessee and in favour of the revenue, since this is a provision in a taxing statute that enables an assessee to get an order passed against him on best judgment basis set aside. The provision must be interpreted in the same manner as an exemption provision in a taxing statute. — JS Fusion Industries Private Limited Vs. The State Tax Officer 1, S GST Department, Ettumanoor and The Commissioner of State GST State GST Department, Tax Towers, Thiruvananthapuram [2019] 16 TAXLOK.COM 054 (Kerala)