1. This hearing has been done through hybrid mode.

2. The present petition has been filed by the Petitioner through its proprietor Mr. Jai Kishan Bansal under Article 226 of the Constitution of India, inter alia, assailing the impugned Show Cause Notice dated 7th August, 2024 issued by the Superintendent, CGST, Delhi North (hereinafter, ‘impugned SCN’) and the impugned order dated 30th January, 2025 passed by the Superintendent, CGST, Delhi North (hereinafter, ‘impugned order’).

3. Vide the impugned order, the total demand confirmed against the Petitioner is set out below:

4. The case of the Department is that an investigation was conducted against 575 noticees in the jurisdiction of CGST North who had availed of fake Input Tax Credit (hereinafter, ‘ITC’) totalling to Rs.13,16,16,906/-. The said ITC availment is alleged to have been facilitated by 16 fake firms. The names of the fake firms are as under:

5. The Petitioner is one of the parties who had availed ITC and is shown as a recipient at Sr. No.3 of Table A of the impugned SCN.

6. Thereafter, the common impugned SCN was issued and several recipients of the SCN filed their replies. However, the Petitioner did not file any reply. Personal hearing was also granted to the Petitioner. However, the Petitioner did not attend the same and thereafter, the impugned order has been passed.

7. In support of the filing of the present writ petition, instead of availing of the appellate remedy under Section 107 of the Central Goods and Services Tax Act, 2017 (hereinafter, ‘CGST Act’) the stand of the Petitioner through Mr. Gaurav Gupta, ld. Counsel for the Petitioner is as under:

i) That the impugned SCN and the impugned order relates to multiple years and the same would not be permissible.

ii) That the tax amounts for each of the years are not specifically delineated and separately reflected in the impugned SCN and the impugned order.

iii) That the personal hearing notices were not received by the Petitioner.

iv) That the jurisdictional officer who has passed the impugned order i.e., the Superintendent, North Range 42, Bawana, Division, did not have the jurisdiction to pass the same.

8. The Court has heard ld. Counsels for the parties. A set of personal hearing notices dated 14th January, 2025 and 20th January, 2025 (hereinafter, ‘personal hearing notices’) have been handed across to the Court.

9. A perusal of the personal hearing notices would show that the personal hearing notices were emailed to the Petitioner on 15th January, 2025 at 2:49:02 PM on the email address jk_ent85@yahoo.com and on 21st January, 2025 at 4:27:54 PM at jk_ent85@yahoo.com.

10. Additionally, the GST portal print out has also been placed on record to show that this is the registered email address of Mr. Jai Kishan Bansal, the proprietor of the Petitioner, whose mobile no. is 9873256990.

11. Clearly, the filing of the present writ petition is without any basis. The Petitioner had a duty to reply to the impugned SCN as the investigation which was conducted by the Department was well within the knowledge of the Petitioner.

12. Further, even after passing of the impugned order, the present writ petition was listed on 30th May, 2025 which is the last day when the three plus one month limitation period, in terms of Section 107(4) of the CGST Act.

13. Moreover, insofar as the issuance of consolidated SCN for multiple financial years is concerned, the said issue stands settled by this Court in the decision in Ambika Traders Through Proprietor Gaurav Gupta V. Additional