DEVAN RAMACHANDRAN, J.

The appellant impugnes the judgment of the learned Single Judge in W.P.(C) No.37027 of 2025, asserting that his client is entitled to challenge Exhibit P2 - Assessment Order, Exhibit P7 - order on Rectification Application and Exhibit P10 - penalty proceedings, under the provisions of the KGST Act , because the fundamental order among them, namely Exhibit P2, had been issued without affording his client any opportunity of being heard.

2. Sri. Tomson T. Emmanuel- learned counsel for the appellant, argued that Exhibit P2 order is unconstitutional and inept in law because, it has been issued denying his client an opportunity of being heard; and consequently, that a writ petition before this Court, challenging it, as also the consequential orders and proceedings, becomes maintainable. He relied upon various precedents, to argue that the law has been well settled that the mere availability of a