Gst Non Filling Return Notice

Department should issue notice under section 46 of the CGST Act 2017 , for non filing of GST return ( GSTR1&GSTR3B) and not under section 125 , if reply was not received under section 46 notice , then best judgement assessment is done by the assessing officer under section 62 of the CGST Act . 

please refer section 46 & 62 of the CGST Act and confirm 

If returns were not filed 

1) Notice under section 46 of the CGST Act 

2) section 62 of the CGST act best judgement assessment is done , if no reply to notice under section 46 within time limit . 

3) late fees under section 47 of the CGST Act applicable 

4) Recovery under section 79 of the CGST Act 2017 

5) possiable demand under section 73 if tax short paid 

So Specific provisions is alrady pricribed in the Act , section 125 of should Gen provsion should be applied , Gen provsion can not override Specfic provisions,

please correct in the last sentence  GEN provision should not be applied .

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