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I therefore allow this Writ petition, on the issue of limitation, applying the ratio of M/s. Cholayil Pvt. Ltd.

Shanti Prime Publication Pvt. Ltd.

GST — The petitioner, a Private Limited Company, is a dealer under KVAT Act, 2003. It faced with the notice issued under Section 25(1) of the KVAT Act. Petitioner sought many reliefs against the respondents in respect of Section 174(1)(i) of the KSG and Services Tax Act, 2017. In case of M/s. Cholayil Pvt. Ltd v. The Assistant Commissioner (Assessment), the question of limitation has been decided by the Division Bench in the petitioner's favour. The writ petition disposed of on the issue of limitation in terms of terms of the judgment delivered in case of M/s. Cholayil Pvt. Ltd. — Earthline Services Private Limited Vs. [2018] 3 TAXLOK.COM 66 (Ker)