I N THE HI GH COURT OF UTTARAKHAND AT NAI NI TAL HON’BLE THE CHIEF JUSTICE SRI MANOJ KUMAR GUPTA AND HON’BLE SRI JUSTICE SUBHASH UPADHYAY WRI T PETI TI ON (M/ B) NO. 876 OF 2025

9^TH APRI L, 2026 Mahesh Kumar Goyal …… Petitioner Versus Assistant Commissioner SGST and another …… Respondents Counsel for the petitioner : Dr. Govind Singh Latwal, learned counsel Counsel for the respondents : Ms. Puja Banga, learned Brief Holder for the State through video conferencing The Court made the following:

JUDGMENT: (per Sri Manoj Kumar Gupta, C.J.)

1) Heard Dr. Govind Singh Latwal, learned counsel for the petitioner and Ms. Puja Banga, learned Brief Holder for the State.

2) The first respondent passed an order dated 07.11.2023 in exercise of power under Section 73 of CGST Act raising a demand of Rs.1,26,773.59 for the period July 2017 to March 2018 on ground of mismatch of certain ITC availed by the petitioner. The petitioner filed an application on 24.06.2025 for rectification of the order under special procedure for rectification notified under Section 148 of the CGST Act, 2017. The application has been rejected on 04.07.2025 for the reason that there does not appear any error apparent on the fa