JUDGMENT :

Bela M. Trivedi, J.

1. The petitioners, by way of the present petition, have challenged the legality and validity of the show-cause notice dated 12.4.2019 (Annexure-D) issued by the respondent No.2 – the Additional Commissioner of Central Goods and Service Tax, Ahmedabad.

2. It may be noted that as stated in paragraph 3.7 of the petition, the petitioners have filed the petition not on the merits of the case, but have challenged the procedural infraction and the manner in which the impugned show-cause notice has been issued by the respondent authority. However, in order to understand the basic controversy it would be necessary to narrate the undisputed facts as transpiring from the record.

3. The petitioner No.1 is a partnership firm engaged in the business of purchase and sale of various textile machineries. The petitioner firm was registered under the erstwhile Sales Tax Regime, and now is also holding a valid and subsisting registration under the present GST Regime. The petitioner firm is holding the Service Tax Registration under the category of business auxiliary services and repair and maintenance services. In and around the year 2009, the petitioner firm had entered in