OD–1 IN THE HIGH COURT AT CALCUTTA CONSTITUTIONAL WRIT JURISDICTION ORIGINAL SIDE WPO/1071/2024 CLIFFORD FACILITES SERVICES PRIVATE LIMITED AND ANR.

VERSUS UNION OF INDIA & ORS.

BEFORE :

THE HON’BLE JUSTICE RAJA BASU CHOWDHURY Date: 8th May, 2025 Appearance :

Mr. Pranit Bag, Adv.

Mr. Anuj Kumar Mishra, Adv.

Ms. Amani Kayan, Adv. Mr. Anousko Das, Adv. Mr. Balram Patra, Adv.

…for the petitioners Mr. Uday Shankar Bhattacharya, Adv.

Mr. Bhaskar Prosad Banerjee, Adv.

Mr. Tapan Bhanja, Adv. …for the CGST Authority The Court :- 1. Challenging the show cause notice dated 31st December, 2020 issued under the provision of Section 73(1) of the first proviso to the Finance Act, 1994 (hereinafter referred to as ‘the said Act’) whereby the respondents have proceeded to invoking the extended period, as also challenging the order in original dated 11th July, 2024 issued by the respondent no.3, the instant writ petition has been filed.

2. Mr. Bag, learned Advocate representing the petitioners by drawing attention of this Court to the showcause notice dated 31st December, 2020 would submit that the said showcause has been issued for the financial year 2015-16, 2016-17 and 2017-18 (April, 2017 to June, 2017) b