IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH HUDSON INSURANCE BROKERS PRIVATE LIMITED ...Petitioner Versus UNION TERRITORY OF CHANDIGARH AND OTHERS ...Respondents

1. The date when the judgment is reserved 20.03.2026 2. The date when the judgment is pronounced 17.04.2026 3. The date when the judgment is uploaded on the website 17.04.2026

4. Whether only operative part of the judgment is pronounced or Full whether the full judgment is pronounced

5. The delay, if any, of the pronouncement of full judgment, and Not applicable reasons thereof CORAM: HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MR. JUSTICE PARMOD GOYAL Present: Ms. Krati Singh, Advocate and Ms. Khushbu Sood, Advocate for the petitioner.

Mr. Sourabh Goel, Sr. Standing Counsel for the respondents.

PARMOD GOYAL, J.

Petitioner has filed the present writ petition under Articles

226/227 of Constitution of India being aggrieved by impugned order dated 24.12.2025 (Annexure P-1), passed by Commercial Tax Officer, Ward-3, Chandigarh (respondent No.2), whereby GST demand has been raised against the petitioner.

2. Petitioner is a company engaged in the business of insurance brokerage and advisory within financial and insurance service sector and is duly registered under GST regime. Notice under Section 61 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as ‘CGST Act’) read with Union Territory Goods and Services Tax Act, 2017 (hereinafter referred to as ‘UTGST Act’) dated 11.08.2025 (Annexure P-2) was issued by respondent No.2 while scrutinizing returns filed by petitioner for the relevant period i.e. year 2021-22 alleging certain discrepancies in the return and calling upon petitioner to furnish explanation and clarification thereon by 25.08.2025 for the discrepancies. In response to notice dated 11.08.2025 (Annexure P-2), petitioner claims to have submitted detailed reply in Form GST-ASMT-11 along with all the relevant documents on 25.08.2025 (Annexure P-3). Despite detailed reply, respondent No.2 issued show cause notice (Annexure P-4) in terms of Section 73(1) of CGST Act read with, UTGST Act. In show cause notice dated 26.09.2025, respondent No.2 had alleged that reply was not found satisfactory as relevant/supporting documents essential for verification of discrepancies were not uploaded.

3. Petitioner vide said show cause notice was directed to submit its reply within 30 days and to appear for personal hearing on 17.10.2025. However, petitioner sought extension of time for filing its reply and also sought adjournment of personal hearing vide its letters dated 13.10.2025 and 16.10.2025 (collectively Annexure P-7). Respondent No.2, however, issued reminder notice dated 27.10.2025 to submit its reply by 04.11.2025 and to attend personal hearing on 03.11.2025. However, as per petitioner it missed to reply to the said reminder notice and requested another opportunity for filing reply and for personal hearing. Subsequently, petitioner had duly filed reply to said show cause notice in Form GST-DRC-06 along with supporting documents on GST portal on 26.11.2025 (Annexure P-5). It is the case of petitioner that despite detailed reply, respondent No.2 proceeded to pass the impugned order confirming demand of Rs.13,42,051/- against the petitioner without considering submissions made therein.

4. The simple case of petitioner in the present case is that the impugned order dated 24.12.2025 (Annexure P-1) raising demand of Rs.13,42,051/- has been passed without considering reply filed by petitioner on 26.11.2025. Petitioner is challenging the impugned order on the ground that same is a non-speaking order and violative of principles of natural justice as it neither deals nor assigns any reason for rejecting the detailed submissions and documentary evidence placed on record by petitioner in its replies to GST-ASMT-11 and show cause notice seeking quashing of impugned order dated 24.12.2025 (Annexure P-1).

5. On the other hand, learned counsel for respondents has argued