THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE SUDDALA CHALAPATHI RAO Writ Petition No.610 of 2023 ORDER: (per Hon’ble Sri Justice P.SAM KOSHY The instant Writ Petition is filed by the petitioner under Article

226 of the Constitution of India praying the Court to issue a Writ, Order or Direction more particularly one in the nature of a Writ of Certiorari calling for the records and to quash the show-cause notice No.V/ST/18/30/2018-Refunds, dated 03.11.2022, issued by respondent No.3 as being wholly without jurisdiction, contrary to the statutory provisions and binding precedents, and also arbitrary, illegal, unjust, contrary to law and without authority of law (for short, ‘the impugned order’)

2. Heard Mr.S. Niranjan Reddy, learned Senior Counsel appearing on behalf of Ms.Rubaina S. Khatoon; and Mr. Bommineni Vivekananda, learned Junior Standing Counsel appearing on behalf of Ms.K. Rajitha, learned Standing Counsel for Union of India, for respondent Nos.1 to 3.

3. The matter revolves around refund of service tax claimed by petitioner in respect of rental income generated by leasing out space for duty-free shops and warehouses at the Rajiv Gandhi International Ai