IN THE HIGH COURT FOR THE STATES OF PUNJAB AND HARYANA AT CHANDIGARH Kuldeep Goyal ...Petitioner Versus Joint Commissioner Preventive Central Goods and Services Tax and another ...Respondents Sr. No. Particulars Details 1 The date when the judgment is reserved 21.04.2026 2 The date when the judgment is pronounced 28.04.2026 3 The date when the judgment is uploaded on the website 28.04.2026 Whether only operative part of the judgment is pronounced or full

4 Full judgment is pronounced The delay, if any, of the pronouncement of full judgment, and Not

5 reasons thereof applicable CORAM: HON'BLE MRS. JUSTICE MANISHA BATRA Present:- Mr. Bipan Ghai, Senior Advocate with Mr. Nikhil Ghai, Advocate for the petitioner.

Mr. Naman Jain, Senior Standing Counsel for respondent No. 1.

Mr. Roshandeep Singh, AAG, Punjab.

MANISHA BATRA, J.

1. Prayer in this petition, filed under Section 482 of Bharatiya Nagarik Suraksha Sanhita, 2023 (for short ‘BNSS’), is for grant of anticipatory bail to the petitioner in pursuance of summons dated 11.03.2026, issued by the respondent No. 1 under Section 70 of Goods and Services Act read with Section 132 of the Central Goods & Service Tax Act, 2017 (for short ‘CGST Act’) with Section 20 of the Integrated Goods and Services Tax, 2017.

2. As per the allegations, in the year 2024, raids were conducted in the premises of M/s Ansh Steel Alloys, which is a firm under the control of the present petitioner a Karta of HUF, qua the purchases made during the assessment years 2019-20, 2020-21 and 2021-22. Summons under Section 70 of the CGST Act were issued to the petitioner giving directions to provide copies of purchase invoices, ledger accounts etc. of M/s Mahadev Multi Metals along with certain other documents on the allegations that the firm M/s Ansh Steel Alloys was involved in receipt of invoices through cancelled firms involving Input Tax Credit (for short ‘ITC’) to the tune of Rs. 35 crores. Qua the assessment year 2019-20, the quantified amount came to be Rs.30,52,350/-. An appeal is pending adjudication qua the said amount before the first appellate authority. Qua the assessment year 2020-21, proceedings were dropped and the proceedings initiated by way of issuance of show cause notice qua the amount quantified with regard to assessment year 2021-22 have been stayed by this Court in a Civil Writ Petition filed by the petitioner and others.

3. Since notice dated 11.03.2026 under Section 70 of the CGST Act has been issued to him by the office of respondent No.1 calling upon him to appear and produce certain documents as well as to record his statement, as such, apprehending that he would be arrested by the respondents, the petitioner moved an application for grant of anticipatory bail before the Court of learned Additional Sessions Judge, Fatehgarh Sahib, which was dismissed, vide order dated 30.03.2026.

4. It is argued by learned senior counsel for the petitioner that qua the notices issued for the previous assessment years, either the proceedings have been dropped, stay order has been passed by this Court or the appeal is pending before the competent authority. On 11.03.2026, a raid was conducted in the premises of his firm on the allegations that his firm was involved in receipt of invoices from cancelled/fictitious firms. These receipts, which are valued at Rs.197.29 crores, are allegedly involving ITC worth Rs. 35 crores. It is argued that qua the proceedings, which have taken place or are pending for the aforementioned assessment years, no notice whatsoever could be issued against the petitioner/his firm in view of the abovementioned facts. With regard to subsequent assessment years, he is ready to join the investigation/inquiry. He is ready to produce all the relevant documents as desired by the respondents-authorities. The case is based on documentary evidence. His custodial interrogation is not at all required. No recovery is to be effected from him. No useful purpose would be served by detaining him into custo