JUDGMENT

Navin Chawla, J. - The above two writ petition(s), being W.P.(C) 2420 of 2021 and W.P.(C) 4036 of 2021, raise a common question of law and are premised on the Circular, bearing D.O. F. No. CBEC/20/43/01/2017-GST (Pt.), dated 05.10.2018, issued by the Central Board of Excise and Customs, New Delhi (hereinafter referred to as the 'CBEC'), and are therefore, being considered and disposed of by this common judgment.

W.P.(C) 2420/2021

2. In W.P.(C) 2420 of 2021, it is the case of the petitioner that it is engaged in the manufacturing and supply of tobacco products. It obtained GST Registration on 21.10.2019 from the jurisdictional Office situated at Gautam Buddh Nagar, Uttar Pradesh, as the petitioner's firm was registered and had its principal place of business within the jurisdiction of the said Commissionerate.

3. The petitioner commenced its commercial operations in the month of December 2019.

4. On 19.03.2020, a search was carried out at the petitioner's premises by the CGST Officers from Gautam Buddh Nagar. The petitioner alleges that no shortcomings were noticed in the said search operation. Thereafter, a Show Cause Notice dated 20.04.2020 was issued by the assistant Commis