Digitally signed by RAME SH 2026:CGHC:11292 KUMAR VATTI Date: 2026.03.16 HIGH COURT OF CHHATTISGARH AT BILASPUR WPT No. 27 of 2026 * - M/s Krishi Vistar Kendra Main Road, Pratappur Surajpur, Chhattisgrh-

497223, Through- Its Sole Proprietor, Kishori Lal Garg ... Petitioner Versus

1 - Union Of India Through- The Joint Secretary, Department Of Revenue, Ministry Of Finance, Having Its Office At Udyog Bhavan, North Block- 110001 (New Delhi )

2 - State Of Chhattisgarh Through The Principal Secretary, Government Of Chhattisgarh At Mahanadi Bhawan, Atal Nagar, Raipur- 492002 ( Chhattisgarh )

3 - State Tax Officer Ambikapur Circle 1, Pratappur Naka, Kulhadi Road, Ambikapur, Surguja ( Chhattisgarh ).

4 - State Bank Of India, through its Branch Manager, Pratappur Branch, Main Road, Surguja - 497227 ( Chhattisgarh.).

... Respondents For Petitioner : Ms. Arya Mittal, Advocate For Respondent No. 1 : Mr. Ramakant Mishra, Deputy Solicitor General For Respondents No. 2 & 3/ : Ms. Anuradha Jain, State Deputy Government Advocate For Respondent No. 4 : Mr. P.R. Patankar, Advocate Hon’ble Shri Justice Rakesh Mohan Pandey

Order on Board

10/03/2026

1. The petitioner has filed this petition seeking the following relief(s):-

“10.1 Issue a Writ of Certiorari or a Writ in the nature of Certiorari, or any other appropriate Writ, Order or directions and call for records and proceedings leading to passing of the Impugned Order and Impugned Rectification Order passed by Respondent No. 3;

10.2 Issue a Writ of Certiorari or a Writ in the nature of Certiorari, or any other appropriate Writ, Order or directions and quashing the Impugned Order dated 28.08.2024 (Annexure P-1) passed by Respondent No. 3, since the same is in violation of principles of natural justice and consequently direct the Respondent No. 3 to re-credit the amount of tax in the Electronic Credit Ledger of the Petitioner which was illegally debited by Respondent No. 3 and direct to de-freeze the bank account of the Petitioner;

10.3 Issue a Writ of Certiorari or a Writ in the nature of Certiorari, or any other appropriate Writ, Order of directions and quashing the Impugned Rectification Order dated 07.10.2025 (Annexure P-2) passed by Respondent No. 3, since the same is ex-facie bad in law, non-speaking and in violation of principles of natural justice;

10.4 Issue a Writ of Mandamus or a Writ in the nature of Mandamus or any other appropriate Writ, Order or directions, restraining the Respondent No. 3 from initiating any further coercive action against the Petitioner under the CGST Act, 2017;

10.5 That any other relief which this Hon’ble Court may deem just and proper in the facts and circumstances of the case may kindly be issued in favour of the petitioners along with the cost of the petition.”

2. The facts in brief are that the petitioner is a sole proprietorship registered the GST laws in the State of Chhattisgarh. It is engaged in the wholesale and retail business of various agricultural products. On 29.04.2024, respondent No. 3 scrutinized the return of the petitioner and issued a notice in Form GST ASMT-10 alleging various discrepancies in the return for the Financial Year 2019-20. On 30.05.2024 respondent No. 3 issued a show cause notice in Form GST DRC-01 proposing a demand of GST to the tune of Rs.33,96,162/- along with interest and penalty for the period of April 2019 to March 2020 under Section 73 of Central Goods and Services Tax Act, 2017 (for short ‘CGST Act’). Respondent No. 3 passed order impugned on 28.08.2024 in Form GST DRC-07 confirming the entire demand of GST to the tune of Rs.64,94,320/-. Respondent No. 3 proceeded to recover the amount of demand on 21.01.2025 and thereafter the petitioner filed rectification application under Section 161 of the CGST Act on 02.03.2025. In between bank account of the petitioner was attached and the application moved by the petitioner for rectification was rejected vide order dated 07.10.2025.

3. Ms. Arya Mittal, learned counsel appearing for the petiti