JUDGMENT

VIBHU BAKHRU, J

1. The petitioner has filed the present petition, inter alia, praying that the respondents be restrained from pursuing the proceedings or taking any further action in respect of the show cause notice dated

27.02.2009 (hereafter ‘the impugned show cause notice’) issued by respondent no.1 – Commissioner of CGST & Central Excise, Goods and Service Tax Commissionerate, Delhi. The petitioner also impugns a letter dated 02.08.2022 (hereafter ‘the impugned letter’) calling upon the petitioner for a personal hearing, and prays that the respondents be restrained from proceeding in any manner pursuant to the impugned letter.

2. The petitioner claims that any such proceedings are barred by limitation as the respondents had failed to conclude the proceedings within a reasonable period from the date of issuance of the impugned show cause notice. The respondents claim that the proceedings pursuant to the impugned show cause notice were kept in abeyance as the matter was placed in a ‘Call Book’ in terms of the Circulars issued by the Central Board of Excise & Customs (hereafter ‘the CBEC’) from time to time.

3. The question that arises for consideration in the present petitio