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Since there is dispute in the interpretation of the legal provisions of section 97(2)(e) of the CGST Act, 2017, which certainly leaves the scope for argument and debate, there is absolutely no question of any error apparent from the face of record, as was being made out by the Appellant.

Maintainability of appeal—The limited issue before us was to ascertain whether there is any error which is apparent on the face of the record i.e. the impugned AAAR Order dated 22.03.2019 as envisaged under section 102 of the CGST Act, 2017. the allegations, made by the Appellant with regard to the error crept in the impugned AAAR Order dated 22.03.2019, which is apparent from the face of record, is without any rationale, and hence do not merit consideration. Held that— We, hereby, reject the application filed by the Appellant under section 102 of the CGST Act, 2017 seeking the amendment in the AAAR Order No. MAH/AAAR/SS-RJ/26/2018-19 dated 22.03.2019.
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