$~17 * IN THE HIGH COURT OF DELHI AT NEW DELHI Date of decision: 30^th March, 2026 + W.P.(C) 2339/2026 AVIK TELEVENTURES PRIVATE LIMITED THROUGH DIRECTOR REGISTERED OFFICE: 8/37, 3RD FLOOR, KIRTI NAGAR INDUSTRIAL AREA, DELHI INDUSTRIAL AREA, WEST DELHI, NEW DELHI- 110015 .....PETITIONER Through: Ms. Kavita Jha, Sr. Advocate with Mr. Nikhil Kohli, Mr. Ishan Gaur and Ms. Saumya Tiwari, Advs.

versus OFFICE OF THE GST OFFICER WARD 71 DEPARTMENT OF TRADE & TAXES GOVERNMENT OF NCT OF DELHI ADDRESS: VYPAR BHAWAN, I.P. ESTATE, NEW DELHI – 110002 .....RESPONDENT Through: Ms. Vaishali Gupta, Panel Counsel (Civil), GNCTD with Mr. Kartik Sharma, Advocate CORAM:

HON’BLE MR. JUSTICE NITIN WASUDEO SAMBRE HON’BLE MR. JUSTICE AJAY DIGPAUL JUDGMENT (ORAL)

AJAY DIGPAUL, J.

1. The prayer in the writ petition reads thus:

“a. Issue a writ of certiorari, or any other appropriate writ, order or direction quashing the Impugned Order dated 31.12.2025 passed by the Respondent, pursuant to the Show Cause Notice dated 24.09.2025, under Section 73 of the Central Goods and Services Tax Act, 2017/ Delhi Goods and Services Tax Act, 2017 imposing an unwarranted liability of Rs. 26,72,64,197/- (Rupees Twenty-Six Crore Seventy-Two Lakh Sixty-Four Thousand One Hundred and Ninety-Seven Only) upon the Petitioner; and b. Issue a writ of certiorari or any other appropriate writ, order or direction quashing and setting aside all consequential proceedings taken in furtherance of the Impugned Order dated 31.12.2025; and c. Pending disposal of the captioned Petition, restrain the Respondent from taking any coercive steps against the Petitioner in furtherance of the Impugned Order dated

31.12.2025; and d. Interim and ad-interim reliefs in terms of prayer clauses (c) above.

e. Pass such other and further orders or directions as this Hon’ble Court may deem fit and proper in the facts and circumstances of the present case.”

2. The petitioner is a company incorporated under the provisions of the Companies Act, 2013, and is engaged in the business of trading and export of branded mobile phones.

3. It is the case of the petitioner that vide email dated 06.12.2024, the respondent informed the petitioner of the appointment of a Special Auditor, viz. M/s DCG & Co., under Section 66 of the Delhi Goods and Services Tax Act, 2017, 1Hereinafter “DGST Act”/Central Goods and Services Tax Act, 2017, Hereinafter “CGST Act”for the purpose of conducting a special audit for the Financial Year 2021-2022.

4. Upon completion of the audit, the said auditor, vide email dated 03.03.2025, communicated its observations regarding certain non-

compliances on the part of petitioner.

5. The petitioner is stated to have furnished a detailed response of the aforesaid observations vide email dated 02.04.2025.

6. It is further the case of the petitioner that thereafter, after a lapse of more than five months, a demand notice dated 11.09.2025 came to be served upon it based on the special audit report dated 27.03.2025, raising a demand of Rs. 33,54,21,609/- and calling upon the petitioner to discharge the same within seven days.

7. Pursuant thereto, a Show Cause Notice dated 24.09.2025, 3Hereinafter “SCN”came to be issued alleging failure to discharge tax liability and proposing a demand of Rs. 58,02,79,384/-, while calling upon the petitioner to furnish its reply within thirty days and to appear for personal hearing on 28.10.2025.

8. According to the petitioner, on 16.10.2025, it sought adjournment of the scheduled personal hearing by a period of ten days. It is further stated that the petitioner, nevertheless, proceeded to file its reply to the SCN on 24.10.2025, along with relevant supporting documents, while reiterating its request for deferment of the personal hearing.

9. However, on 27.12.2025, the petitioner received an email from the respondent issuing Reminder-1, calling upon it to submit a further response by 29.12.2025 and to appear for a personal hearing on

30.12.2025.

10. Thereafter, the respondent passed the Ord