| S.No | Name | Date of Order | Subject | Actions |
|---|---|---|---|---|
| 1 | Abdul Majid & Ors. v. Assistant Commissioner of Commercial Taxes & Anr. | 05-09-2026 | Anticipatory Bail in Proceedings under Section 70 CGST Act — Arrest and Custodial Interrogation under Sections 69 & 132 | View Download |
BackgroundThe petitioners were proprietors of registered firms dealing in steel and scrap materials. They had purchased aluminium scrap from certain supplier firms. The authorities subsequently conducted raids at the premises of the suppliers and arrested their proprietors. Thereafter, summons were issued to the petitioners under Section 70 of the CGST Act, requiring them to appear and produce supporting documents concerning the purchases. The petitioners apprehended arrest and approached the Court after their applications for anticipatory bail before the Sessions Court were dismissed.The prosecution alleged that the suppliers had issued concocted invoices without actual supply of goods and that the petitioners had availed ITC on the basis of such invoices, with the tax amounts allegedly being encashed through hawala transactions. The petitioners, on the other hand, maintained that they had paid the invoice value and GST through banking transactions, had periodically filed their returns and were willing to produce documents such as e-way bills, transport records, weighbridge receipts and stock/sale records to establish actual receipt of goods.Court ObservationThe Court observed that ITC cannot ordinarily be denied to a purchaser merely because the supplier's registration is subsequently cancelled or the supplier ceases to exist after the transaction. Where the supplier was registered and active at the time of the transaction, the purchaser had paid the invoice value and GST through banking channels and had filed returns, recovery would ordinarily be against the defaulting supplier unless fraud and collusion are proved or exceptional circumstances exist.The Court further held that actual receipt of goods can be established through documentary evidence such as e-way bills, transport vehicle receipts, weighbridge receipts and stock and sale records. In a genuine transaction, where the purchaser has paid the invoice value and GST and regularly filed returns, custodial interrogation would normally not be necessary merely to verify receipt of goods, unless there is prima facie material showing collusion with the supplier.The Court emphasised that arrest under Section 69 read with Section 132 cannot be based merely on suspicion. The Commissioner must have a belief supported by material and evidence satisfying the statutory conditions. The Court also noted that, for the purpose of Section 132, the supplier is the principal offender in the circumstances considered in the case.The Court also considered the petitioners' cooperation, absence of similar antecedents, payment through banking channels and undertaking to produce documents. It relied upon the principle that where an accused has joined investigation, is cooperating and is not likely to abscond, custodial interrogation should be avoided.Final VerdictThe High Court allowed all three petitions and granted anticipatory bail. The respondents/authorities were directed to release the petitioners in the event of their arrest in connection with the proceedings under Section 132(1) of the CGST Act, subject to specified conditions.The petitioners were directed to appear before the authorities on 10.08.2026 and could be taken into custody for interrogation if necessary, but were to be released on the same day after interrogation, subject to execution of a ₹5 lakh personal bond with two sureties of the like amount. They were also required to cooperate with the investigation, avoid influencing witnesses, keep their mobile numbers operational, provide their location through Google Maps, surrender their passports and not leave India without permission.Cases Referred by the CourtCaseCourt Radhika Agarwal v. Union of IndiaSupreme Court of India Akram Pasha v. Senior Intelligence Officer, DGGIHigh Court of Karnataka Tarun Jain v. Directorate General of GST Intelligence (DGGI)High Court of Delhi Siddharam Satlingappa Mhetre v. State of Maharashtra & Ors.Supreme Court of India Shailesh Rajpal v. CommissionerHigh Court of Madhya Pradesh GST Intelligence Directorate v. Chaman GoelHigh Court of Delhi The Court distinguished Shailesh Rajpal and Chaman Goel because those cases involved different factual circumstances concerning the suppliers and tax/ITC allegations, whereas the present case concerned purchasers who claimed payment of invoice value and GST through banking channels and were willing to establish actual receipt of goods.The Court particularly relied upon Radhika Agarwal, Akram Pasha, Tarun Jain and Siddharam Satlingappa Mhetre while assessing the legality and necessity of arrest/custodial interrogation. | ||||
| Abdul Majid & Ors. v. Assistant Commissioner of Commercial Taxes & Anr. 05-09-2026 Anticipatory Bail in Proceedings under Section 70 CGST Act — Arrest and Custodial Interrogation under Sections 69 & 132BackgroundThe petitioners were proprietors of registered firms dealing in steel and scrap materials. They had purchased aluminium scrap from certain supplier firms. The authorities subsequently conducted raids at the premises of the suppliers and arrested their proprietors. Thereafter, summons were issued to the petitioners under Section 70 of the CGST Act, requiring them to appear and produce supporting documents concerning the purchases. The petitioners apprehended arrest and approached the Court after their applications for anticipatory bail before the Sessions Court were dismissed.The prosecution alleged that the suppliers had issued concocted invoices without actual supply of goods and that the petitioners had availed ITC on the basis of such invoices, with the tax amounts allegedly being encashed through hawala transactions. The petitioners, on the other hand, maintained that they had paid the invoice value and GST through banking transactions, had periodically filed their returns and were willing to produce documents such as e-way bills, transport records, weighbridge receipts and stock/sale records to establish actual receipt of goods.Court ObservationThe Court observed that ITC cannot ordinarily be denied to a purchaser merely because the supplier's registration is subsequently cancelled or the supplier ceases to exist after the transaction. Where the supplier was registered and active at the time of the transaction, the purchaser had paid the invoice value and GST through banking channels and had filed returns, recovery would ordinarily be against the defaulting supplier unless fraud and collusion are proved or exceptional circumstances exist.The Court further held that actual receipt of goods can be established through documentary evidence such as e-way bills, transport vehicle receipts, weighbridge receipts and stock and sale records. In a genuine transaction, where the purchaser has paid the invoice value and GST and regularly filed returns, custodial interrogation would normally not be necessary merely to verify receipt of goods, unless there is prima facie material showing collusion with the supplier.The Court emphasised that arrest under Section 69 read with Section 132 cannot be based merely on suspicion. The Commissioner must have a belief supported by material and evidence satisfying the statutory conditions. The Court also noted that, for the purpose of Section 132, the supplier is the principal offender in the circumstances considered in the case.The Court also considered the petitioners' cooperation, absence of similar antecedents, payment through banking channels and undertaking to produce documents. It relied upon the principle that where an accused has joined investigation, is cooperating and is not likely to abscond, custodial interrogation should be avoided.Final VerdictThe High Court allowed all three petitions and granted anticipatory bail. The respondents/authorities were directed to release the petitioners in the event of their arrest in connection with the proceedings under Section 132(1) of the CGST Act, subject to specified conditions.The petitioners were directed to appear before the authorities on 10.08.2026 and could be taken into custody for interrogation if necessary, but were to be released on the same day after interrogation, subject to execution of a ₹5 lakh personal bond with two sureties of the like amount. They were also required to cooperate with the investigation, avoid influencing witnesses, keep their mobile numbers operational, provide their location through Google Maps, surrender their passports and not leave India without permission.Cases Referred by the CourtCaseCourt Radhika Agarwal v. Union of IndiaSupreme Court of India Akram Pasha v. Senior Intelligence Officer, DGGIHigh Court of Karnataka Tarun Jain v. Directorate General of GST Intelligence (DGGI)High Court of Delhi Siddharam Satlingappa Mhetre v. State of Maharashtra & Ors.Supreme Court of India Shailesh Rajpal v. CommissionerHigh Court of Madhya Pradesh GST Intelligence Directorate v. Chaman GoelHigh Court of Delhi The Court distinguished Shailesh Rajpal and Chaman Goel because those cases involved different factual circumstances concerning the suppliers and tax/ITC allegations, whereas the present case concerned purchasers who claimed payment of invoice value and GST through banking channels and were willing to establish actual receipt of goods.The Court particularly relied upon Radhika Agarwal, Akram Pasha, Tarun Jain and Siddharam Satlingappa Mhetre while assessing the legality and necessity of arrest/custodial interrogation. | ||||
| 2 | The Commissioner of Central Tax, Mysore Audit Commissionerate & Ors. vs. Sadguru Infratech Pvt Ltd. | 10-06-2026 | Whether a writ court can direct the GST authorities to permit filing/amendment of returns while waiving interest, penalty and limitation under the GST Acts, and to refrain from precipitative action, in respect of the incremental tax burden arising from th | View Download |
BackgroundThis is the Revenue's appeal against a Single Judge order dated 11.04.2023 (a common order in a batch led by Sri. Chandrashekaraiah v. State of Karnataka) which had allowed the writ petitioner's (Sadguru Infratech's) writ and issued directions to the tax authorities and contracting parties. The writ petitioner, a sub-contractor in a lift irrigation works contract, had challenged interest demands and recovery action for delayed GST payment, contending the rates were fixed pre-GST and did not include GST. The Revenue confined its appeal to the directions issued to the tax authorities.FactsThe writ petitioner, registered under KVAT and later under GST with effect from 01.07.2017, is a sub-contractor and constituent of the main contractor (a JV) awarded a lift irrigation and canal works contract by Karnataka Neeravari Nigam Limited (KNNL). The main contract dated 06.03.2017 and the sub-contract dated 24.06.2017 were both entered into at the Schedule of Rates prevailing under the VAT regime, which did not include the element of GST. With the GST Acts coming into force on 01.07.2017, the works contract became subject to GST at 18% (01.07.2017 to 21.08.2017) and 12% thereafter, increasing the writ petitioner's tax liability. The writ petitioner filed its returns for 2017-18, 2018-19 and 2019-20 belatedly, with delay in payment of self-assessed tax occurring on as many as twenty-six occasions, ranging from one day to 338 days.The GST authorities issued a notice dated 13.02.2020 in Form GST ASMT-10 demanding interest on delayed payment under Section 50, followed by a notice dated 19.02.2020, and initiated recovery by a notice dated 18.03.2020 in Form GST DRC-13 under Section 79(1)(c) to the writ petitioner's banker. The Single Judge allowed the writ and, among other directions, permitted petitioners to file returns/amended returns post-01.07.2017 by calculating differential tax in a prescribed manner without insisting on interest, penalty or limitation, directed the GST authorities not to take precipitative action for six months, and directed reimbursement of the differential tax by the concerned employer. The Revenue appealed only against the directions to the tax authorities, contending that interest under Section 50 is mandatory with no discretion to waive or reduce, and that there is no provision enabling filing or amendment of returns in the manner directed. The short question was whether the Single Judge could have issued such directions to the tax authorities.Court Observations (Verbatim)Para 9: "The dispute as to whether the writ petitioner would be entitled to reimbursement of the incremental tax paid or payable by it on account of the levy of GST is strictly a matter between the contracting parties - writ petitioner and the main contractor - with whom it had entered into the contract. The contract between the said parties or the contract between the main contractor and KNNC would not alter the statutory scheme for the levy of GST... The question of the levy of GST, assessment, recovery, and enforcement is a matter of statutory prescription."Para 10: "It is well settled that the liability to pay interest on delayed payment of tax under a fiscal statute arises by operation of law, leaving no discretion in the authority to waive or reduce, if the statute makes no such provision (see Pratibha Processors v. Union of India, (1996) 11 SCC 101). The directions in the impugned order waiving interest, penalty, and limitation, and permitting the filing or amendment of returns in a manner not contemplated by the statute, therefore cannot be sustained."Para 11: "In view of the above, the directions issued permitting the filing of any revised returns contrary to the provisions of the statute are unsustainable. The blanket directions to waive the penalty, interest under the GST Acts or the limitation for filing returns/revised returns are also unsustainable."Para 12: "The controversy as to which party is required to bear the incremental tax burden arising on account of the change in the tax regime is, in essence, one between the contracting parties. In the context of such a dispute, no directions could be issued to the tax authorities regarding the levy, assessment, and collection of tax, penalty, or interest."Para 13: "In the aforesaid view, the direction issued to the respondents to reimburse the tax is required to be construed as a direction only to the concerned party with whom the writ petitioner had entered into the contract and not to the tax authorities."VerdictThe Revenue's appeal was allowed. The Division Bench held that interest under Section 50 arises by operation of law with no discretion to waive, and that directions waiving interest, penalty and limitation and permitting filing/amendment of returns contrary to the statute are unsustainable. The direction to reimburse tax was construed as binding only the contracting party (main contractor), not the tax authorities. The impugned Single Judge order, insofar as it relates to W.P. No. 10163/2020, was set aside.Cases Referred by the CourtPratibha Processors v. Union of India — (1996) 11 SCC 101 (relied upon: liability to pay interest on delayed tax under a fiscal statute arises by operation of law, leaving no discretion to waive or reduce absent statutory provision)Order under challenge (not a precedent):Sri. Chandrashekaraiah & Ors. v. The State of Karnataka — W.P. No. 9721/2019 and connected matters (including W.P. No. 10163/2020), decided 11.04.2023 (the impugned common Single Judge order) | ||||
| The Commissioner of Central Tax, Mysore Audit Commissionerate & Ors. vs. Sadguru Infratech Pvt Ltd. 10-06-2026 Whether a writ court can direct the GST authorities to permit filing/amendment of returns while waiving interest, penalty and limitation under the GST Acts, and to refrain from precipitative action, in respect of the incremental tax burden arising from thBackgroundThis is the Revenue's appeal against a Single Judge order dated 11.04.2023 (a common order in a batch led by Sri. Chandrashekaraiah v. State of Karnataka) which had allowed the writ petitioner's (Sadguru Infratech's) writ and issued directions to the tax authorities and contracting parties. The writ petitioner, a sub-contractor in a lift irrigation works contract, had challenged interest demands and recovery action for delayed GST payment, contending the rates were fixed pre-GST and did not include GST. The Revenue confined its appeal to the directions issued to the tax authorities.FactsThe writ petitioner, registered under KVAT and later under GST with effect from 01.07.2017, is a sub-contractor and constituent of the main contractor (a JV) awarded a lift irrigation and canal works contract by Karnataka Neeravari Nigam Limited (KNNL). The main contract dated 06.03.2017 and the sub-contract dated 24.06.2017 were both entered into at the Schedule of Rates prevailing under the VAT regime, which did not include the element of GST. With the GST Acts coming into force on 01.07.2017, the works contract became subject to GST at 18% (01.07.2017 to 21.08.2017) and 12% thereafter, increasing the writ petitioner's tax liability. The writ petitioner filed its returns for 2017-18, 2018-19 and 2019-20 belatedly, with delay in payment of self-assessed tax occurring on as many as twenty-six occasions, ranging from one day to 338 days.The GST authorities issued a notice dated 13.02.2020 in Form GST ASMT-10 demanding interest on delayed payment under Section 50, followed by a notice dated 19.02.2020, and initiated recovery by a notice dated 18.03.2020 in Form GST DRC-13 under Section 79(1)(c) to the writ petitioner's banker. The Single Judge allowed the writ and, among other directions, permitted petitioners to file returns/amended returns post-01.07.2017 by calculating differential tax in a prescribed manner without insisting on interest, penalty or limitation, directed the GST authorities not to take precipitative action for six months, and directed reimbursement of the differential tax by the concerned employer. The Revenue appealed only against the directions to the tax authorities, contending that interest under Section 50 is mandatory with no discretion to waive or reduce, and that there is no provision enabling filing or amendment of returns in the manner directed. The short question was whether the Single Judge could have issued such directions to the tax authorities.Court Observations (Verbatim)Para 9: "The dispute as to whether the writ petitioner would be entitled to reimbursement of the incremental tax paid or payable by it on account of the levy of GST is strictly a matter between the contracting parties - writ petitioner and the main contractor - with whom it had entered into the contract. The contract between the said parties or the contract between the main contractor and KNNC would not alter the statutory scheme for the levy of GST... The question of the levy of GST, assessment, recovery, and enforcement is a matter of statutory prescription."Para 10: "It is well settled that the liability to pay interest on delayed payment of tax under a fiscal statute arises by operation of law, leaving no discretion in the authority to waive or reduce, if the statute makes no such provision (see Pratibha Processors v. Union of India, (1996) 11 SCC 101). The directions in the impugned order waiving interest, penalty, and limitation, and permitting the filing or amendment of returns in a manner not contemplated by the statute, therefore cannot be sustained."Para 11: "In view of the above, the directions issued permitting the filing of any revised returns contrary to the provisions of the statute are unsustainable. The blanket directions to waive the penalty, interest under the GST Acts or the limitation for filing returns/revised returns are also unsustainable."Para 12: "The controversy as to which party is required to bear the incremental tax burden arising on account of the change in the tax regime is, in essence, one between the contracting parties. In the context of such a dispute, no directions could be issued to the tax authorities regarding the levy, assessment, and collection of tax, penalty, or interest."Para 13: "In the aforesaid view, the direction issued to the respondents to reimburse the tax is required to be construed as a direction only to the concerned party with whom the writ petitioner had entered into the contract and not to the tax authorities."VerdictThe Revenue's appeal was allowed. The Division Bench held that interest under Section 50 arises by operation of law with no discretion to waive, and that directions waiving interest, penalty and limitation and permitting filing/amendment of returns contrary to the statute are unsustainable. The direction to reimburse tax was construed as binding only the contracting party (main contractor), not the tax authorities. The impugned Single Judge order, insofar as it relates to W.P. No. 10163/2020, was set aside.Cases Referred by the CourtPratibha Processors v. Union of India — (1996) 11 SCC 101 (relied upon: liability to pay interest on delayed tax under a fiscal statute arises by operation of law, leaving no discretion to waive or reduce absent statutory provision)Order under challenge (not a precedent):Sri. Chandrashekaraiah & Ors. v. The State of Karnataka — W.P. No. 9721/2019 and connected matters (including W.P. No. 10163/2020), decided 11.04.2023 (the impugned common Single Judge order) | ||||
| 3 | Sumukha Ventures vs. Joint Commissioner of Commercial Taxes & Ors. | 24-04-2026 | Challenge to Show Cause Notice and Order-in-Original passed by the same officer who conducted the audit proceedings — violation of principles of natural justice under GST. | View Download |
BackgroundSumukha Ventures, a partnership firm based in Bengaluru, was subjected to proceedings initiated by both the audit authority and the enforcement authority under GST. The Deputy Commissioner of Commercial Taxes (Audit)-3.7 issued a Show Cause Notice dated 30.09.2025 (Form GST DRC-01, Reference No. ZD290925221988K). Thereafter, an Order-in-Original (Annexure-B) was passed by the same officer who had conducted the audit proceedings. The petitioner filed a Writ Petition under Articles 226 and 227 of the Constitution of India before the High Court of Karnataka challenging both the Show Cause Notice and the Order-in-Original. Court Observations (Verbatim)"It is submitted that such action is impermissible and being in violation of principles of natural justice, insofar as the authority while conducting audit has expressed its opinion and findings are recorded at one stage. It is submitted that once again if the same officer were to conduct the assessment proceedings, the authority would be guided by the findings made in the audit report.""Taking note that this identical question is often raised by assessees, it would be appropriate that this aspect has the benefit of adjudication by the appropriate authority. By keeping open all contentions raised, the matter is remitted to respondent No.2.""The petitioner to take their stand before respondent No.2, regarding the aspect of jurisdiction as raised in the present petition. Upon such objection being raised, it is open for the authority to obtain necessary orders on the administrative side from the authority which assigns i.e., the Joint Commissioner of Commercial Taxes (Administration) - respondent No.1.""Taking note of the nature of objection raised, the authority to record a finding of their aspect of jurisdiction as per the procedure referred to above and only thereafter, consider the proceedings on merits.""Needless to state, no steps to be taken on merits till finding is recorded in terms of the observations made." Final VerdictThe Order-in-Original (Annexure-B) was set aside and the matter was remitted to Respondent No. 2 (Deputy Commissioner) to first decide the question of jurisdiction — specifically whether the same officer who conducted the audit can also pass the adjudication order — before proceeding on merits. The petition was disposed of accordingly. Citations / Circulars ReferredReferenceDetailsCircular No. 31/05/2018-GSTDated 09.02.2018 (Annexure-AB) — referred by Petitioner regarding impermissibility of same officer conducting audit and adjudicationCircular No. 169/01/2022-GSTDated 12.03.2022 (Annexure-AC) — referred by Petitioner on same issue | ||||
| Sumukha Ventures vs. Joint Commissioner of Commercial Taxes & Ors. 24-04-2026 Challenge to Show Cause Notice and Order-in-Original passed by the same officer who conducted the audit proceedings — violation of principles of natural justice under GST.BackgroundSumukha Ventures, a partnership firm based in Bengaluru, was subjected to proceedings initiated by both the audit authority and the enforcement authority under GST. The Deputy Commissioner of Commercial Taxes (Audit)-3.7 issued a Show Cause Notice dated 30.09.2025 (Form GST DRC-01, Reference No. ZD290925221988K). Thereafter, an Order-in-Original (Annexure-B) was passed by the same officer who had conducted the audit proceedings. The petitioner filed a Writ Petition under Articles 226 and 227 of the Constitution of India before the High Court of Karnataka challenging both the Show Cause Notice and the Order-in-Original. Court Observations (Verbatim)"It is submitted that such action is impermissible and being in violation of principles of natural justice, insofar as the authority while conducting audit has expressed its opinion and findings are recorded at one stage. It is submitted that once again if the same officer were to conduct the assessment proceedings, the authority would be guided by the findings made in the audit report.""Taking note that this identical question is often raised by assessees, it would be appropriate that this aspect has the benefit of adjudication by the appropriate authority. By keeping open all contentions raised, the matter is remitted to respondent No.2.""The petitioner to take their stand before respondent No.2, regarding the aspect of jurisdiction as raised in the present petition. Upon such objection being raised, it is open for the authority to obtain necessary orders on the administrative side from the authority which assigns i.e., the Joint Commissioner of Commercial Taxes (Administration) - respondent No.1.""Taking note of the nature of objection raised, the authority to record a finding of their aspect of jurisdiction as per the procedure referred to above and only thereafter, consider the proceedings on merits.""Needless to state, no steps to be taken on merits till finding is recorded in terms of the observations made." Final VerdictThe Order-in-Original (Annexure-B) was set aside and the matter was remitted to Respondent No. 2 (Deputy Commissioner) to first decide the question of jurisdiction — specifically whether the same officer who conducted the audit can also pass the adjudication order — before proceeding on merits. The petition was disposed of accordingly. Citations / Circulars ReferredReferenceDetailsCircular No. 31/05/2018-GSTDated 09.02.2018 (Annexure-AB) — referred by Petitioner regarding impermissibility of same officer conducting audit and adjudicationCircular No. 169/01/2022-GSTDated 12.03.2022 (Annexure-AC) — referred by Petitioner on same issue | ||||
| 4 | Sri Padmavathi Marketing v. Assistant Commissioner of Commercial Taxes | 04-03-2026 | Scope of Rule 86A – Whether ITC can be blocked for supplier when alleged wrongful availment is by recipient. | View Download |
Case Facts:The petitioner challenged a show-cause notice proposing blocking of ITC under Rule 86A and seeking restoration of ₹1.96 crore. The allegation was that the petitioner issued invoices without actual supply of goods, enabling M/s. Million Lights to avail wrongful ITC. The petitioner contended that Rule 86A applies only when ITC is wrongly availed by the assessee itself and not by its customer. The department asserted ongoing investigation and alleged admissions regarding issuance of invoices without supply.Court Decision:The Court held that Rule 86A empowers restriction on utilization of ITC only when the credit in the electronic credit ledger of the concerned assessee is fraudulently availed or is ineligible under specified circumstances such as absence of supply, non-existent supplier, non-payment of tax, or lack of valid documents. The Rule is limited to these conditions and cannot be invoked otherwise. In the present case, the allegation was that the petitioner issued invoices without actual supply, leading to wrongful ITC availment by the recipient. Such allegation does not pertain to ITC availed by the petitioner itself. Therefore, invocation of Rule 86A against the petitioner was improper as the statutory conditions were not satisfied. | ||||
| Sri Padmavathi Marketing v. Assistant Commissioner of Commercial Taxes 04-03-2026 Scope of Rule 86A – Whether ITC can be blocked for supplier when alleged wrongful availment is by recipient.Case Facts:The petitioner challenged a show-cause notice proposing blocking of ITC under Rule 86A and seeking restoration of ₹1.96 crore. The allegation was that the petitioner issued invoices without actual supply of goods, enabling M/s. Million Lights to avail wrongful ITC. The petitioner contended that Rule 86A applies only when ITC is wrongly availed by the assessee itself and not by its customer. The department asserted ongoing investigation and alleged admissions regarding issuance of invoices without supply.Court Decision:The Court held that Rule 86A empowers restriction on utilization of ITC only when the credit in the electronic credit ledger of the concerned assessee is fraudulently availed or is ineligible under specified circumstances such as absence of supply, non-existent supplier, non-payment of tax, or lack of valid documents. The Rule is limited to these conditions and cannot be invoked otherwise. In the present case, the allegation was that the petitioner issued invoices without actual supply, leading to wrongful ITC availment by the recipient. Such allegation does not pertain to ITC availed by the petitioner itself. Therefore, invocation of Rule 86A against the petitioner was improper as the statutory conditions were not satisfied. | ||||
| 5 | Anchor Shipping Services v. Assistant Commissioner of Commercial Taxes | 20-02-2026 | Challenge to ex parte GST assessment orders on grounds of improper service and violation of natural justice | View Download |
Facts :The petitioner, a registered GST dealer, was subjected to assessment proceedings under Section 73 of the CGST/KGST Act for certain tax periods. Discrepancies were found between GSTR-3B, GSTR-1, and GSTR-2A returns, leading to issuance of show-cause notices through the GST portal. The petitioner contended that such notices and consequent ex parte orders were not effectively communicated and came to light only during recovery proceedings. Due to lack of knowledge, the statutory appeal period expired.Court Decision:The Court held that uploading notices on the GST portal is a valid mode of service under Section 169, and a registered dealer is expected to monitor such communications. However, since the impugned orders were ex parte and had serious civil consequences, the Court balanced equities and set aside the orders. The matter was remitted for fresh adjudication subject to conditions: appearance before authority, filing objections, deposit of 20% of tax, and payment of ₹75,000 as costs. Non-compliance would result in revival of the original orders. | ||||
| Anchor Shipping Services v. Assistant Commissioner of Commercial Taxes 20-02-2026 Challenge to ex parte GST assessment orders on grounds of improper service and violation of natural justiceFacts :The petitioner, a registered GST dealer, was subjected to assessment proceedings under Section 73 of the CGST/KGST Act for certain tax periods. Discrepancies were found between GSTR-3B, GSTR-1, and GSTR-2A returns, leading to issuance of show-cause notices through the GST portal. The petitioner contended that such notices and consequent ex parte orders were not effectively communicated and came to light only during recovery proceedings. Due to lack of knowledge, the statutory appeal period expired.Court Decision:The Court held that uploading notices on the GST portal is a valid mode of service under Section 169, and a registered dealer is expected to monitor such communications. However, since the impugned orders were ex parte and had serious civil consequences, the Court balanced equities and set aside the orders. The matter was remitted for fresh adjudication subject to conditions: appearance before authority, filing objections, deposit of 20% of tax, and payment of ₹75,000 as costs. Non-compliance would result in revival of the original orders. | ||||
| 6 | NL Tile Art Private Limited vs. Additional Commissioner of Commercial | 18-12-2025 | Validity of revision proceedings based on audit report – Section 108 of the CGST Act, 2017 / KGST Act, 2017 read with Sections 73 and 74 of the CGST/KGST Act. | View Download |
Facts:Audit reports dated 06.12.2022 and 22.02.2023 were issued in respect of the petitioner. Based on the audit observations, the respondent issued a revision notice dated 05.11.2025 under Section 108(1) of the CGST/KGST Act proposing revision of the audit report. The petitioner challenged the notice contending that revision proceedings under Section 108 cannot be initiated merely to revise an audit report without first initiating proceedings under Sections 73 or 74 of the Act.Court Decision:The High Court held that Section 65(7) of the KGST Act provides that where an audit detects unpaid or short-paid tax or wrongful availment of input tax credit, the proper officer must initiate action under Section 73 or Section 74 of the Act. The Court observed that in the present case no proceedings under Sections 73 or 74 had been initiated prior to issuing the revision notice under Section 108.Following the earlier judgment of the same Court, the Court held that revisional powers under Section 108 cannot be invoked to revise an audit report in the absence of proceedings under Sections 73 or 74. Consequently, the revision notice dated 05.11.2025 was held to be without jurisdiction and was quashed, while granting liberty to the authorities to initiate appropriate proceedings in accordance with law.Cases Referred by Court:Navayuga Engineering Company Limited vs. Joint Commissioner of Commercial TaxesRadha Krishan Industries vs. State of Himachal Pradesh | ||||
| NL Tile Art Private Limited vs. Additional Commissioner of Commercial 18-12-2025 Validity of revision proceedings based on audit report – Section 108 of the CGST Act, 2017 / KGST Act, 2017 read with Sections 73 and 74 of the CGST/KGST Act.Facts:Audit reports dated 06.12.2022 and 22.02.2023 were issued in respect of the petitioner. Based on the audit observations, the respondent issued a revision notice dated 05.11.2025 under Section 108(1) of the CGST/KGST Act proposing revision of the audit report. The petitioner challenged the notice contending that revision proceedings under Section 108 cannot be initiated merely to revise an audit report without first initiating proceedings under Sections 73 or 74 of the Act.Court Decision:The High Court held that Section 65(7) of the KGST Act provides that where an audit detects unpaid or short-paid tax or wrongful availment of input tax credit, the proper officer must initiate action under Section 73 or Section 74 of the Act. The Court observed that in the present case no proceedings under Sections 73 or 74 had been initiated prior to issuing the revision notice under Section 108.Following the earlier judgment of the same Court, the Court held that revisional powers under Section 108 cannot be invoked to revise an audit report in the absence of proceedings under Sections 73 or 74. Consequently, the revision notice dated 05.11.2025 was held to be without jurisdiction and was quashed, while granting liberty to the authorities to initiate appropriate proceedings in accordance with law.Cases Referred by Court:Navayuga Engineering Company Limited vs. Joint Commissioner of Commercial TaxesRadha Krishan Industries vs. State of Himachal Pradesh | ||||
| 7 | Metal N Strips vs. Joint Commissioner of Commercial Tax (Appeals-3) & Anr. | 17-10-2025 | Penalty exceeding amount specified in show cause notice – Sections 74(1), 74(9), 75(7), 75(13) and Section 122(1)(vii) of the CGST Act / KGST Act, 2017. | View Download |
Facts:The petitioner challenged the adjudication order dated 30.06.2023 passed under Section 74 of the KGST Act read with Section 122(1)(vii), which demanded tax, interest and a penalty of ₹6,05,17,933. In the show cause notice dated 27.03.2023, tax and penalty were proposed in equal amounts. However, while passing the final order, the authority drastically reduced the tax and interest liability but increased the penalty amount far beyond the penalty proposed in the show cause notice. The appellate authority dismissed the appeal confirming the penalty.Court Decision:The High Court held that Section 74(1) permits imposition of penalty only up to an amount equivalent to the tax specified in the show cause notice. Section 75(7) further provides that the amount demanded in the final order cannot exceed the amount specified in the show cause notice and cannot be based on grounds other than those mentioned in the notice.The Court observed that in the present case the tax and interest amounts were reduced in the final order, but the penalty was increased beyond the amount proposed in the show cause notice and also beyond the tax determined in the order. Such action was contrary to Sections 74 and 75 of the KGST Act.Accordingly, the Court set aside the impugned orders to the extent of the penalty demand of ₹6,05,17,933 and remitted the matter back to the adjudicating authority for fresh consideration limited to the issue of penalty, while directing the petitioner to pay the confirmed tax and interest amounts. | ||||
| Metal N Strips vs. Joint Commissioner of Commercial Tax (Appeals-3) & Anr. 17-10-2025 Penalty exceeding amount specified in show cause notice – Sections 74(1), 74(9), 75(7), 75(13) and Section 122(1)(vii) of the CGST Act / KGST Act, 2017.Facts:The petitioner challenged the adjudication order dated 30.06.2023 passed under Section 74 of the KGST Act read with Section 122(1)(vii), which demanded tax, interest and a penalty of ₹6,05,17,933. In the show cause notice dated 27.03.2023, tax and penalty were proposed in equal amounts. However, while passing the final order, the authority drastically reduced the tax and interest liability but increased the penalty amount far beyond the penalty proposed in the show cause notice. The appellate authority dismissed the appeal confirming the penalty.Court Decision:The High Court held that Section 74(1) permits imposition of penalty only up to an amount equivalent to the tax specified in the show cause notice. Section 75(7) further provides that the amount demanded in the final order cannot exceed the amount specified in the show cause notice and cannot be based on grounds other than those mentioned in the notice.The Court observed that in the present case the tax and interest amounts were reduced in the final order, but the penalty was increased beyond the amount proposed in the show cause notice and also beyond the tax determined in the order. Such action was contrary to Sections 74 and 75 of the KGST Act.Accordingly, the Court set aside the impugned orders to the extent of the penalty demand of ₹6,05,17,933 and remitted the matter back to the adjudicating authority for fresh consideration limited to the issue of penalty, while directing the petitioner to pay the confirmed tax and interest amounts. | ||||
| 8 | Klassic Traders vs. State of Karnataka & Others | 25-09-2024 | Quashing of ECL blocking order under Rule 86A of CGST Rules, 2017 passed without pre-decisional hearing and without independent 'reasons to believe', based solely on borrowed satisfaction from Enforcement authority reports | View Download |
BackgroundThe petitioner, Klassic Traders, a proprietary concern registered under GST, had ITC of Rs.43,18,514 available in its Electronic Credit Ledger (ECL). By order dated 06.06.2024, the Assistant Commissioner of Commercial Taxes, LGSTO-16, Bengaluru blocked the petitioner's ECL by invoking Rule 86A of the CGST Rules. No pre-decisional hearing was given to the petitioner before passing this order. The blocking order contained no independent reason to believe as to why the ECL needed to be blocked; it merely relied upon Enforcement authority reports stating that a registered supplier was found non-existent or not conducting business from its registered place. No independent application of mind was applied by the blocking authority. The petitioner challenged the blocking order by way of a writ petition before the Karnataka High Court seeking quashing of the order and unblocking of ITC, and also sought a declaration that Rule 86A is ultra vires Section 16(2) of the CGST Act. Court Observations (Verbatim / Near-Verbatim)"In the instant case, since no pre-decisional hearing was provided/granted by the respondents before passing the impugned order, coupled with the fact that the impugned order invoking Section 86A of the CGST Rules by blocking of the Electronic credit ledger of the petitioner does not contain independent or cogent reasons to believe except by placing reliance upon the reports of Enforcement authority which is impermissible in law, since the same is on borrowed satisfaction as held by the Hon'ble Division Bench of this Court, the impugned order deserves to be quashed.""It is also pertinent to note that in the impugned order except stating that 'a registered supplier who has been found to be non-existent or not to be conducting business from his place of registration', no other reasons are forthcoming in the impugned order. On this ground also, the impugned order dated 06.06.2024 deserves to be quashed."The Court further relied upon and reproduced the binding ratio from K-9-Enterprises (Division Bench), including:"The expression 'reason to believe' would necessarily mean that the respondents must arrive at a satisfaction based on their own independent inquiry and not upon borrowed inquiry.""A bonafide purchaser cannot be denied ITC on account of a supplier's default and the recipient cannot be made to suffer denial of ITC for the wrong doings of the supplier.""The impugned orders are bald, vague, cryptic, laconic, unreasoned and non-speaking and deserve to be set aside." Final VerdictThe writ petition was allowed. The blocking order dated 06.06.2024 was quashed. The respondents were directed to immediately unblock the ECL of the petitioner upon receipt of the order to enable filing of returns forthwith. Liberty was reserved to the respondents to proceed against the petitioner in accordance with law and in terms of the Division Bench judgment in K-9-Enterprises. 👍 | ||||
| Klassic Traders vs. State of Karnataka & Others 25-09-2024 Quashing of ECL blocking order under Rule 86A of CGST Rules, 2017 passed without pre-decisional hearing and without independent 'reasons to believe', based solely on borrowed satisfaction from Enforcement authority reportsBackgroundThe petitioner, Klassic Traders, a proprietary concern registered under GST, had ITC of Rs.43,18,514 available in its Electronic Credit Ledger (ECL). By order dated 06.06.2024, the Assistant Commissioner of Commercial Taxes, LGSTO-16, Bengaluru blocked the petitioner's ECL by invoking Rule 86A of the CGST Rules. No pre-decisional hearing was given to the petitioner before passing this order. The blocking order contained no independent reason to believe as to why the ECL needed to be blocked; it merely relied upon Enforcement authority reports stating that a registered supplier was found non-existent or not conducting business from its registered place. No independent application of mind was applied by the blocking authority. The petitioner challenged the blocking order by way of a writ petition before the Karnataka High Court seeking quashing of the order and unblocking of ITC, and also sought a declaration that Rule 86A is ultra vires Section 16(2) of the CGST Act. Court Observations (Verbatim / Near-Verbatim)"In the instant case, since no pre-decisional hearing was provided/granted by the respondents before passing the impugned order, coupled with the fact that the impugned order invoking Section 86A of the CGST Rules by blocking of the Electronic credit ledger of the petitioner does not contain independent or cogent reasons to believe except by placing reliance upon the reports of Enforcement authority which is impermissible in law, since the same is on borrowed satisfaction as held by the Hon'ble Division Bench of this Court, the impugned order deserves to be quashed.""It is also pertinent to note that in the impugned order except stating that 'a registered supplier who has been found to be non-existent or not to be conducting business from his place of registration', no other reasons are forthcoming in the impugned order. On this ground also, the impugned order dated 06.06.2024 deserves to be quashed."The Court further relied upon and reproduced the binding ratio from K-9-Enterprises (Division Bench), including:"The expression 'reason to believe' would necessarily mean that the respondents must arrive at a satisfaction based on their own independent inquiry and not upon borrowed inquiry.""A bonafide purchaser cannot be denied ITC on account of a supplier's default and the recipient cannot be made to suffer denial of ITC for the wrong doings of the supplier.""The impugned orders are bald, vague, cryptic, laconic, unreasoned and non-speaking and deserve to be set aside." Final VerdictThe writ petition was allowed. The blocking order dated 06.06.2024 was quashed. The respondents were directed to immediately unblock the ECL of the petitioner upon receipt of the order to enable filing of returns forthwith. Liberty was reserved to the respondents to proceed against the petitioner in accordance with law and in terms of the Division Bench judgment in K-9-Enterprises. 👍 | ||||
| 9 | Veremax Technologie Services Limited vs Assistant Commissioner of Central Tax | 04-09-2024 | Show Cause Notice – Clubbing of multiple financial years in a single show cause notice under Section 73 of the CGST Act, 2017 – validity of consolidated show cause notice. | View Download |
Facts:The petitioner challenged the show cause notice dated 03.05.2024 and the Order-in-Original dated 21.11.2023 issued under Section 73 of the CGST/IGST/SGST Acts for the financial years 2017-18 (July 2017 to March 2018), 2018-19, 2019-20 and 2020-21. The petitioner contended that the department issued a single consolidated show cause notice covering multiple tax periods instead of issuing separate notices for each financial year.Court Decision:The Court held that under Section 73 of the CGST Act, the limitation period of three years for passing an order is calculated separately from the due date of furnishing the annual return for each financial year. Consequently, actions relating to different financial years must be treated independently.Relying on the principles laid down by the Supreme Court and the Madras High Court, the Court held that issuance of a single consolidated show cause notice for multiple financial years is contrary to the statutory scheme of the CGST Act.Accordingly, the Court allowed the writ petition and quashed the show cause notice dated 03.05.2024 issued for the tax periods 2017-18 to 2020-21. The Court clarified that the respondent is at liberty to issue separate show cause notices for each assessment year in accordance with Section 73 of the CGST Act.Cases Referred by Court:· Titan Company Ltd. v. Joint Commissioner of GST, W.P. No.33164 of 2023 (Madras High Court)· State of Jammu and Kashmir and Others v. Caltex (India) Ltd., AIR 1966 SC 1350 | ||||
| Veremax Technologie Services Limited vs Assistant Commissioner of Central Tax 04-09-2024 Show Cause Notice – Clubbing of multiple financial years in a single show cause notice under Section 73 of the CGST Act, 2017 – validity of consolidated show cause notice.Facts:The petitioner challenged the show cause notice dated 03.05.2024 and the Order-in-Original dated 21.11.2023 issued under Section 73 of the CGST/IGST/SGST Acts for the financial years 2017-18 (July 2017 to March 2018), 2018-19, 2019-20 and 2020-21. The petitioner contended that the department issued a single consolidated show cause notice covering multiple tax periods instead of issuing separate notices for each financial year.Court Decision:The Court held that under Section 73 of the CGST Act, the limitation period of three years for passing an order is calculated separately from the due date of furnishing the annual return for each financial year. Consequently, actions relating to different financial years must be treated independently.Relying on the principles laid down by the Supreme Court and the Madras High Court, the Court held that issuance of a single consolidated show cause notice for multiple financial years is contrary to the statutory scheme of the CGST Act.Accordingly, the Court allowed the writ petition and quashed the show cause notice dated 03.05.2024 issued for the tax periods 2017-18 to 2020-21. The Court clarified that the respondent is at liberty to issue separate show cause notices for each assessment year in accordance with Section 73 of the CGST Act.Cases Referred by Court:· Titan Company Ltd. v. Joint Commissioner of GST, W.P. No.33164 of 2023 (Madras High Court)· State of Jammu and Kashmir and Others v. Caltex (India) Ltd., AIR 1966 SC 1350 | ||||
| 10 | K-9 Enterprises vs. State of Karnataka | 02-04-2024 | Legality of blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 without pre-decisional hearing and without independent application of mind. | View Download |
BackgroundThe appellants — GST-registered businesses dealing in lead, lead scrap and allied goods — had availed Input Tax Credit (ITC) on purchases from GST-registered suppliers, which stood credited in their Electronic Credit Ledgers (ECL). The tax authorities, acting on a field visit report of the Assistant State Tax Officer, Vasco-da-Gama, Goa (an officer from another jurisdiction), which found certain suppliers to be non-existent or not conducting business from their registered place, issued orders dated 27.06.2023 blocking the ECL of the appellants by invoking Rule 86A of the CGST Rules, 2017. No pre-decisional hearing was granted to the appellants before blocking the ECL. The appellants challenged these orders before the Single Judge by way of writ petitions, which were disposed of rejecting the appellants' contentions. Aggrieved, the appellants filed the present intra-court writ appeals before the Division Bench. Court Observations (Verbatim / Near-Verbatim)On Pre-Decisional Hearing (Point No. 1):"Though Rule 86A does not expressly/specifically provide for adherence to principles of natural justice, the same would necessarily have to be read into Rule 86A and complied with while invoking the said provision.""When the ECL of the appellants was sought to be blocked and such credit cannot be utilised for upto 1 year, the said blocking would entail and result in serious civil consequences for the appellants warranting compliance with the principles of natural justice and providing an opportunity of hearing to the appellants.""Ordinarily, a post-decisional hearing is not a substitute for pre-decisional hearing and that pre-decisional hearing is important especially when the respondents-revenue passed the impugned orders which would entail and visit the appellants with serious civil consequences.""It was not physically possible for the appellants to immediately/forthwith encash/withdraw the ITC available in its ECL so as to warrant emergent/urgent blocking of the ECL without providing a pre-decisional hearing to the appellants.""Respondents-revenue committed a grave and serious error/illegality/infirmity in not providing/granting a pre-decisional hearing to the Appellant before passing the impugned order blocking its Electronic Credit Ledger under Rule 86A of the CGST Rules."On 'Reasons to Believe' and Independent Application of Mind (Point No. 2):"Rule 86A, which in effect is the power to block ECL is drastic in nature which creates a disability for the taxpayer to avail of the credit in ECL for discharge of his tax liability which he is otherwise entitled to avail and therefore, all the requirements of Rule 86A would have to be fully complied with before the power thereunder is exercised; when this Rule requires arriving at a subjective satisfaction which is evident from the use of words, 'must have reasons to believe', the satisfaction must be reached on the basis of some objective material available before the authority and cannot be made on the flights of ones fancies or whims or caprices.""The electronic credit ledgers have been blocked solely on the basis of communication from another officer [Field visit report by the Asst. State Tax Officer, Vasco-D-Gama, (Goa)]. There was no tangible material to form any belief that the ITC lying in the appellants' ECL was on account of any fake invoice; it had proceeded to take action solely on the basis of a direction issued by another authority.""The impugned orders have been passed based on the communication received from other officers, without any independent application of mind. This shows that exercise of power under Rule 86A was not because he was independently satisfied about the need for blocking the ECL but, was due to the fact that he felt compelled to obey the command of another officer.""The impugned order discloses that the same has been passed mechanically and is based on borrowed satisfaction and does not meet the test of formation of an opinion... the impugned orders are bald, vague, cryptic, laconic, unreasoned and non-speaking and deserve to be set aside.""It is quite possible that the transaction, when entered into in 2017 or 2018 could be genuine and when the officer visits in 2020 or 2021, the business could have been closed and therefore the mere closure of business in 2020 or 2021 cannot be a basis for denying credit availed earlier.""A bonafide purchaser cannot be denied ITC on account of a supplier's default and the recipient cannot be made to suffer denial of ITC for the wrong doings of the supplier." Final VerdictAll six writ appeals were allowed. The common order of the Single Judge dated 27.07.2023 and all the ECL blocking orders dated 27.06.2023 / 02.06.2023 were set aside and quashed. 👍 | ||||
| K-9 Enterprises vs. State of Karnataka 02-04-2024 Legality of blocking of Electronic Credit Ledger (ECL) under Rule 86A of CGST Rules, 2017 without pre-decisional hearing and without independent application of mind.BackgroundThe appellants — GST-registered businesses dealing in lead, lead scrap and allied goods — had availed Input Tax Credit (ITC) on purchases from GST-registered suppliers, which stood credited in their Electronic Credit Ledgers (ECL). The tax authorities, acting on a field visit report of the Assistant State Tax Officer, Vasco-da-Gama, Goa (an officer from another jurisdiction), which found certain suppliers to be non-existent or not conducting business from their registered place, issued orders dated 27.06.2023 blocking the ECL of the appellants by invoking Rule 86A of the CGST Rules, 2017. No pre-decisional hearing was granted to the appellants before blocking the ECL. The appellants challenged these orders before the Single Judge by way of writ petitions, which were disposed of rejecting the appellants' contentions. Aggrieved, the appellants filed the present intra-court writ appeals before the Division Bench. Court Observations (Verbatim / Near-Verbatim)On Pre-Decisional Hearing (Point No. 1):"Though Rule 86A does not expressly/specifically provide for adherence to principles of natural justice, the same would necessarily have to be read into Rule 86A and complied with while invoking the said provision.""When the ECL of the appellants was sought to be blocked and such credit cannot be utilised for upto 1 year, the said blocking would entail and result in serious civil consequences for the appellants warranting compliance with the principles of natural justice and providing an opportunity of hearing to the appellants.""Ordinarily, a post-decisional hearing is not a substitute for pre-decisional hearing and that pre-decisional hearing is important especially when the respondents-revenue passed the impugned orders which would entail and visit the appellants with serious civil consequences.""It was not physically possible for the appellants to immediately/forthwith encash/withdraw the ITC available in its ECL so as to warrant emergent/urgent blocking of the ECL without providing a pre-decisional hearing to the appellants.""Respondents-revenue committed a grave and serious error/illegality/infirmity in not providing/granting a pre-decisional hearing to the Appellant before passing the impugned order blocking its Electronic Credit Ledger under Rule 86A of the CGST Rules."On 'Reasons to Believe' and Independent Application of Mind (Point No. 2):"Rule 86A, which in effect is the power to block ECL is drastic in nature which creates a disability for the taxpayer to avail of the credit in ECL for discharge of his tax liability which he is otherwise entitled to avail and therefore, all the requirements of Rule 86A would have to be fully complied with before the power thereunder is exercised; when this Rule requires arriving at a subjective satisfaction which is evident from the use of words, 'must have reasons to believe', the satisfaction must be reached on the basis of some objective material available before the authority and cannot be made on the flights of ones fancies or whims or caprices.""The electronic credit ledgers have been blocked solely on the basis of communication from another officer [Field visit report by the Asst. State Tax Officer, Vasco-D-Gama, (Goa)]. There was no tangible material to form any belief that the ITC lying in the appellants' ECL was on account of any fake invoice; it had proceeded to take action solely on the basis of a direction issued by another authority.""The impugned orders have been passed based on the communication received from other officers, without any independent application of mind. This shows that exercise of power under Rule 86A was not because he was independently satisfied about the need for blocking the ECL but, was due to the fact that he felt compelled to obey the command of another officer.""The impugned order discloses that the same has been passed mechanically and is based on borrowed satisfaction and does not meet the test of formation of an opinion... the impugned orders are bald, vague, cryptic, laconic, unreasoned and non-speaking and deserve to be set aside.""It is quite possible that the transaction, when entered into in 2017 or 2018 could be genuine and when the officer visits in 2020 or 2021, the business could have been closed and therefore the mere closure of business in 2020 or 2021 cannot be a basis for denying credit availed earlier.""A bonafide purchaser cannot be denied ITC on account of a supplier's default and the recipient cannot be made to suffer denial of ITC for the wrong doings of the supplier." Final VerdictAll six writ appeals were allowed. The common order of the Single Judge dated 27.07.2023 and all the ECL blocking orders dated 27.06.2023 / 02.06.2023 were set aside and quashed. 👍 | ||||
