IN THE HIGH COURT OF ORISSA AT CUTTACK W.P.(C) No.33058 of 2025 M/s. Simon India Ltd. …. Petitioner Mr. Jagabandhu Sahoo, Senior Advocate assisted by Ms. Kajal Sahoo, Advocate -versus-

Assistant Commissioner of CT & …. Opposite Parties GST, Jagatsinghpur and others Mr. Sunil Mishra, Standing Counsel for CT & GST Department CORAM:

THE HON’BLE THE CHIEF JUSTICE AND THE HON’BLE MR. JUSTICE MURAHARI SRI RAMAN

ORDER

Order No. 16.12.2025

04. 1. Heard Mr. Jagabandhu Sahoo, learned Senior appearing along with Ms. Kajal Sahoo, learned counsel for the petitioner and Mr. Sunil Mishra, learned Standing Counsel appearing for the CT & GST Department.

2. The Petitioner, a company registered under the Companies Act, 1956, on introduction of the Central Goods and Services Tax Act, 2017/the Odisha Goods and Services Tax Act, 2017 (collectively, “GST Act”), is allotted with GSTIN/ID:21AAECS5013J1ZQ. It undertook execution of works contracts being entrusted by M/s. OCL India Limited and M/s. Paradeep Phosphate Limited. The transactions were reflected in the returns filed under Section 39 of the GST Act.

2.1. The company was subjected to audit under Section 65 of the GST Act and was issued with a show-cause