JUDGMENT (Per Jitendra Jain J):-

1. Rule. By consent of the parties taken on production board and heard finally since only legal issue is involved.

2. By this petition under Article 226 of the Constitution of India, the petitioner seeks to challenge the notice dated 21 August 2024 issued under Section 65 of the Maharashtra Goods and Services Tax Act, 2017 (“SGST Act”) in Form No. GST ADT-01 read with Rule 101 of the Goods and Services Tax Rules, 2017 (GST Rules) by which the respondents seek to conduct an audit for the financial year 2020-21. Consequently, the petitioner also aims to challenge the preliminary audit findings dated 11 October 2024.

Brief facts :-

3. The petitioner was engaged in the rental and leasing services of commercial properties and other ancillary activities relating to the same.

4. On 2 March 2019, the petitioner was issued a registration certificate under the Central Goods and Services Tax Act, 2017 (CGST Act). After conducting business since then, on 27 March 2023, the petitioner applied for cancellation of its CGST registration on the ground that they have ceased to be liable to pay tax on account of the closure of business. On 2 May 2023, the respondents passe