JUDGMENT :

The petitioner is a company incorporated under the Companies Act, 1956, and is wholly owned by the Government of Kerala. It is primarily engaged in the business of conducting chits. It is before this Court challenging Ext.P1 show cause notice dated 21-04-2022 interaliacalling upon the petitioner to show cause as to why Goods and Services Tax (GST) amounting to Rs.61,55,21,173/-(Rupees Sixty-one Crores Fifty-five Lakhs Twenty-one Thousand one Hundred Seventy-three only) should not be demanded and recovered under the provisions of Section 74 of the Central Goods and Services Tax/State Goods and Services Tax Acts, 2017, (CGST/SGST Acts), as to why interest should not be demanded on the aforesaid sum and as to why penalty should not be imposed in terms of the provisions contained in the CGST/SGST Acts for violation of the provisions of the law.

2. According to the petitioner, Ext.P1 show cause notice is clearly without jurisdiction and is liable to be quashed in the exercise of the jurisdiction vested in this Court under Article 226 of the Constitution of India. Though Exts. P5 to P8 notifications are challenged, it is submitted for the petitioner that the challenge to those n