JUDGMENT :

The instant writ petition seeking to invoke the extra-ordinary and discretionary jurisdiction of this Court under Article 226 of the Constitution of India is preferred to assail a Demand-cum-Show Cause Notice bearing no. GADT/CnG/ADT/GST/6758/2021-Gr-22-CGST-SLCR ADT CIR-ADT SHILLONG/308 [‘Demand-cum-Show Cause Notice’, for short] dated 22.09.2023 issued under sub-section [1] of Section 73 of the Central Goods and Services Tax Act, 2017 [hereinafter referred to as ‘the CGST Act, 2017’, for short] and an Order-in- Original bearing no. 15/GST/AC/SIL/2023-24 [‘Order-in-Original’, for short] dated 14.12.2023 passed under sub-section [9] of Section 73 of the CGST Act, 2017 by the Assistant Commissioner, Central [Goods and Service Tax] & Central Excise Division, Silchar as the Adjudicating Authority.

2. The writ petitioner herein is a private limited company incorporated under the Companies Act, 1956 and it carries on the business inter alia of service provider. It has its registered office at Kolkata, West Bengal. With the enactments of the CGST Act, 2017 and the Assam Goods and Services Act, 2017 [‘the AGST Act, 2017] and their coming into effect w.e.f. 01.07.2017, the pet