No refund of tax paid during the search where taxpayer accepted liability and raised no objection for two years

The Petitioner was operating a coaching institute, Alpha-1 Tuition Classes and Hostel, without obtaining GST registration despite crossing the threshold for registration. During a search conducted by GST authorities under Section 67(2) of the Gujarat Goods and Services Tax Act [GGST Act] from 6 October 2023 to 10 October 2023, various documents were seized and statements were recorded.

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