1.Heard Sri V. Lakshmikumaran learned Counsel for the petitioner and Sri N. Venkataraman, learned Additional Solicitor General of India and Sri P.R. Sreejith learned Senior Standing Counsel for the Central Board of Indirect Taxes and Customs (CBIC) on behalf of the respondents.

2. These two writ petitions have been filed by the petitioner/Asianet Digital Network Private Ltd, a Company registered under the provisions of the Companies Act impugning two show cause notices in Ext.P1 in both the writ petitions issued under Section 73 of the Central Goods and Services Tax Act 2017 (for short, ‘CGST Act’) for the period February 2017 to June 2017 in W.P.(C) No.30147/2022 and from July 2017 to March 2020 in W.P.(C) No.3611/2024.

Facts in brief:

3. In October 2015, Asianet Broadband Private Ltd was formed as a wholly owned subsidiary of Asianet Satellite Communications Ltd (for short, ‘Parent Company’). ‘Asianet Broadband Private Ltd’ was renamed ‘Asianet Digital Cable TV Private Ltd’ in March 2017 and again renamed ‘Asianet Digital Network Private Ltd’ in January 2018.

3.1 During the initial period i.e., 1993-2000, the Parent Company used to provide cable television services directly to the su