IN THE HIGH COURT AT CALCUTTA CONSTITUTIONAL WRIT JURISDICTION APPELLATE SIDE Before:

The Hon’ble Justice Om Narayan Rai WPA 10415 of 2025 Sunrise Timply Company Pvt. Ltd.

vs.

Union of India & Ors.

For the Petitioner : Mr. Avra Mazumder, Adv.

Ms. Alisha Das, Adv.

Mr. Suman Bhowmik, Adv.

Ms. Elina Dey, Adv.

Ms. Rupomita Ghosh, Adv.

For the State : Mr. S.K. Dutt, Adv.

Mr. Saptak Sanyal, Adv.

Mr. Debraj Sahu, Adv.

For the CGST Authority : Mr. Shiv Shankar Banerjee, Adv.

Mr. Bijiresh Mukherjee, Adv.

Hearing Concluded on : 19.01.2026 Judgment on : 19.01.2026 Om Narayan Rai, J.:-

1. This writ petition assails an order in original dated January 30, 2025 passed under Section 74 of the Central Goods and Services Act, 2017/ West Bengal Goods and Service Tax Act, 2017 (hereafter the said Act of 2017) as well as an order dated March 25, 2025 passed by the Proper Officer thereby rejecting the petitioner’s application for rectification.

FACTS OF THE CASE:

2. A proceeding under Section 74 of the said Act of 2017 had been initiated against the petitioner by issuing a notice to show cause dated September 8, 2021 alleging that the petitioner had failed to make payment of Integrated Goods and Services Tax (hereafter