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2025 Supreme(Ker) 2950

IN THE HIGH COURT OF KERALA AT ERNAKULAM
ZIYAD RAHMAN A.A.
P.P. Paul – Appellant
Versus
Union Of India, Secretary, Ministry Of Finance, Department Of Revenue – Respondent


Advocates Appeared:
For the Petitioner: Shri. Sasidharan I.P., Shri. Ramanarayanan G.
For the Respondents: Shri. C. Dinesh, CGC, Sri. P.T. Dinesh.

Table of Content
1. petitioner challenges tax recovery proceedings. (Para 1 , 2 , 3)
2. controversy over entitlement to amnesty scheme. (Para 4 , 5)
3. court hears arguments from both parties. (Para 6 , 10)
4. dispute over extension of limitation based on supreme court orders. (Para 7 , 8)
5. court analyses statutory provisions applicable to the case. (Para 9 , 11)
6. quasi-judicial nature of the administrative proceedings. (Para 14 , 20)
7. court concludes proceedings are quasi-judicial and entitled to extension. (Para 21 , 22 , 23)
8. court orders issuance of compliance certificate based on timely payment. (Para 24 , 28)

JUDGMENT :

ZIYAD RAHMAN A.A., J. 

This writ Petition is submitted by the petitioner, being aggrieved by the revenue recovery proceedings initiated against the petitioner towards the arrears of service tax payable by the petitioner.

2. Earlier, proceedings were initiated against the petitioner, demanding service tax as per Ext.P1 show cause notice. Exhibit P2 is yet another show cause notice issued to the petitioner following Ext.P1. In the meantime, the Central Government introduced a scheme for settlement of the tax liabilities including service tax viz; Sabka Vishwas (Lega

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