JUDGMENT :

1. This is a writ petition under Article 226 of the Constitution of India, wherein the petitioner is aggrieved by order dated September 14, 2021 passed by Assistant Commissioner, State Tax, Sector-2, Fatehpur under Section 74 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as “the Act”) for the tax period 2018-19 and the appellate order dated October 5, 2023 passed by the Additional Commissioner, Grade-2, (Appeal)-III, State Tax, Prayagraj.

2. The first ground taken by the learned counsel for the petitioner is that the petitioner had cancelled its registration voluntarily on September 18, 2019, whereas the notice under Section 74 of the Act was given to it only by way of uploading the same on the web portal on a subsequent date. He submits that the notice, that has been issued, was issued in the year 2021 or in late December 2020 as the date fixed for hearing was January 12, 2021. He further submits that as the petitioner had already cancelled its registration voluntarily, it was not required to check the web portal. Further ground has also been taken by the learned counsel for the petitioner with regard to the respondent No.3 proceeding on the bas