ORDER :

1. Heard Mr. P. Karthik Ramana, learned counsel for the petitioner; Mr. B. Narasimha Sharma, learned counsel for respondents 1 and 2, Mr. Krishna Swamy for the learned Assistant Solicitor General of India appearing for respondent No. 3 and Sri. K. Raji Reddy, learned counsel for respondents 4 and 5.

2. By filing this petition under Article 226 of the Constitution of India, petitioner has assailed legality and validity of Order-in- Original dated 28.03.2019 passed by respondent No. 1 under Section 73 of the Central Goods and Services Tax Act, 2017 (briefly ‘the Act’ hereinafter).

3. From a perusal of the Order-in-Original, we find that petitioner had failed to file Goods and Service Tax (GST) returns since October, 2017 to December, 2018. After the discussions and findings recorded in paragraph No. 10 of the Order-in-Original, respondent No. 1 passed the following order:

(a) I confirm the demand of Rs. 1,54,76,440/- (rupees one crore fifty four lakhs seventy six thousand four forty only), which is the tax amount not paid during the period December, 2017 to December, 2018 as per Section 73(1) of the CGST Act, 2017 read with section 20 of IGST Act, 2017.

(b) I order for recovery of