THE HON’BLE THE CHIEF JUSTICE SRI APARESH KUMAR SINGH AND THE HON’BLE SRI JUSTICE G.M.MOHIUDDIN WRIT PETITION No.27627 of 2025

ORDER:

Learned counsel Sri Kohir Bhaskar Reddy appears for the petitioner.

Sri Dominic Fernandes, learned Senior Standing Counsel for Central Board of Indirect Taxes and Customs (CBIC), appears for respondents No.1 and 3.

2. The writ petition has been preferred against the order-in-original dated 04.07.2024 passed under Section 73 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as, “the Act”), for the tax periods 2021 – 2022 and 2022 – 2023 imposing the tax, penalty and interest.

3. The petitioner has approached this Court alleging that the proceedings have been conducted through a composite show cause notice covering different years, which is illegal and contrary to the provisions of the Act. The petitioner has asserted at paragraph 5 of the writ affidavit that neither the show cause notice nor the notice of personal hearing was served or uploaded in the GST portal. The petitioner has come to know about the liability only upon the issuance of the garnishee notice in Form GST DRC-13 on 04.06.2025 for attachment of its Bank account (Ann