ORDER:

Learned counsel Sri K.P.Amarnath 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 to 3.

2. Heard the learned counsel for the parties.

3. Both the order-in-original dated 17.11.2024 along with the summary of the order in Form GST DRC-07 dated 21.11.2024 and the appellate order dated 12.03.2026 pertaining to the financial years 2017 - 18 to 2022 - 23 are under challenge by the petitioner, whereby the respondents have fastened GST liability, including Reverse Charge Mechanism (RCM) liability on raw cotton transactions, despite the petitioner’s specific contention that the purchases were made for trading purposes.

4. The impugned proceedings have been conducted by invoking both Sections 73 and 74 of the Central Goods and Services Tax Act, 2017 (hereinafter referred to as, “the Act”). After availing the appellate remedy, the petitioner has approached this court with the contention that the appellate authority failed to appreciate the detailed explanations, invoices, e-way bills, bank statements, reconciliation statements and other supporting documents furnis