Kerala High Court
Chovakkaran Joseph Elsy vs Assistant Commissioner on 12 June, 2024
Author: Dinesh Kumar Singh
Bench: Dinesh Kumar Singh
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 286 OF 2023
PETITIONER:
BABU MATHEW,AGED 72 YEARS
C.CINEMAS, CHIPPY MOVIE HOUSE, CHENGANNUR, ALAPPUZHA
DISTRICT, PIN - 689121
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 THE STATE TAX OFFICER,STATE GST DEPARTMENT, CHENGANNUR,
ALAPPUZHA, PIN - 689121
2 THE JOINT COMMISSIONER (APPEALS),STATE GST DEPARTMENT,
TAXES COMPLEX, ASRAMAM, KOLLAM, PIN - 691002
3 UNION OF INDIA,
REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF
FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW
DELHI, PIN - 110001
4 CENTRAL BOARD OF INDIRECT TAXES 0& CUSTOMS,
GST POLICY WING, NORTH BLOCK, NEW DELHI -110001,
REPRESENTED BY PRINCIPAL COMMISSIONER (GST).
5 STATE OF KERALA,
REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPT.,
GOVT. SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001
OTHER PRESENT:
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).906/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 2
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 906 OF 2023
PETITIONER:
SAJI MATHACHAN,AGED 53 YEARS
M/SKURUPPASSERYGLASS & PLY WOODS, VI/682-C, SUVARNA
JUBILEE MANDIRAM, MUNAMBAM JN; VADAKKEKARA , ERNAKULAM
REPRESENTED BY ITS PROPRIETOR. SRI. SAJI MATHACHAN, PIN
- 683522
BY ADVS.
M.K.HAJARA
K.K.MOHINUDHEEN
AABID ALI K.
RESPONDENTS:
1 THE STATE TAX OFFICER,STATE GOODS & SERVICES TAX
DEPARTMENT, NORTH PARAVUR , ERNAKULAM, PIN - 683513
2 UNION OF INDIA,REPRESENTED BY ITS SECRETARY (REVENUE),
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI, PIN - 110001
3 THE CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
REPRESENTED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI, PIN - 110001
4 STATE OF KERALA
REPRESENTED BY ITS SECRETARY TO TAXES, SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
BY ADV THOMAS MATHEW NELLIMOOTTIL
SRI. MUHAMED RAFIQ-SPL.GP
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 3
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 1412 OF 2023
PETITIONER:
CENTRAL KERALA GRANITES
MEKALADY, KALADY -P. O, ERNAKULAM -, REPRESENTED BY ITS
PROPRIETOR SRI. M.A. ABDUL KHADAR, PIN - 683574
BY ADVS.
AJI V.DEV
ALAN PRIYADARSHI DEV
S.SAJEEVAN
RESPONDENTS:
1 THE STATE TAX OFFICER
STATE GOODS AND SERVICES TAX DEPARTMENT, THOTTAKKARA
BUILDING, ANGAMALY, PIN - 683572
2 UNION OF INDIA,REPRESENTED BY ITS SECRETARY (REVENUE),
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI -, PIN - 110001
3 THE CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS,
REPRESENTED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI -, PIN - 110001
4 THE STATE OF KERALA
REPRESENTED BY ITS SECRETARY TAXES DEPARTMENT,
SECRETARIAT, THIRUVANANTHAPURAM -, PIN - 695001
BY ADV Thanuja Roshan George
SRI. MUHAMED RAFIQ-SPL.GP
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 4
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 1977 OF 2023
PETITIONER:
R. RAM MANOJ, PROPRIETOR, A. M. BODY BUILDERS
AGED 52 YEARS,PORUVAZHY, PANAPETTY, BHARANICAVU,
SASTHAMCOTTA, KOLLAM, PIN - 690520
BY ADVS.
V.DEVANANDA NARASIMHAM
M.FASALUDEEN
FIBIN.F
RESPONDENTS:
1 STATE TAX OFFICER ( WORKS CONTRACT),KSGST DEPARTMENT,
BAPUJI NAGAR, ASRAMAM, KOLLAM, PIN - 691002
2 STATE OF KERALA REPRESENTED BY ITS SECRETARY
DEPARTMENT OF TAXES, SECRETARIAT, THIRUVANANTHAPURAM,
PIN - 695001
3 UNION OF INDIA REPRESENTED BY ITS SECRETARY
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NEW DELHI.,
PIN - 110023
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 5
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 2070 OF 2023
PETITIONER:
M/S WINSOM PLASTICS
TMC/V/382-A, OLAMATTOM, THODUPUZHA, IDUKKI REPRESENTED
BY ITS MANAGING PARTNER SRI RINTU RAJ, PIN - 685584
BY ADVS.
AJI V.DEV
ALAN PRIYADARSHI DEV
S.SAJEEVAN
RESPONDENTS:
1 THE DEPUTY COMMISSIONER OF STATE TAX,STATE GOODS AND
SERVICES TAX DEPARTMENT, 2ND FLOOR, TAX COMPLEX,
PALLIKKAVALA, KATTAPPANA SOUTH PO, IDUKKI, PIN - 685515
2 UNION OF INDIA,REPRESENTED BY ITS SECRETARY (REVENUE),
MINISTRY OF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI, PIN - 110001
3 THE CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS,
REPRESNETED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI, PIN - 110001
4 THE STATE OF KERALA
REPRESENTED BY ITS SECRETARY, TAXES DEPARTMENT,
SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001
BY ADV DENNIS VARGHESESRI. MUHAMED RAFIQ-SPL.GP
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 6
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 2735 OF 2023
PETITIONER:
ASIAN STEEL PIPES AND FITTINGS,DOOR NO. 10/712, 10/715,
NHANGHATTIRI POST, PALAKKAD, REPRESENTED BY ITS
PROPRIETOR SRI. V. MOHAMMED SHAREEF, PIN - 679303
BY ADVS.
K.S.HARIHARAN NAIR
HARIMA HARIHARAN
RAJATH R NATH
G.REMADEVI
RESPONDENTS:
1 STATE TAX OFFICER,
STATE GOODS AND SERVICES TAX DEPARTMENT, STATE GST
OFFICE, MINI CIVIL STATION, PATTAMBI, PIN - 679303
2 UNION OF INDIA,REPRESENTED BY SECRETARY, DEPARTMENT OF
REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI,
PIN - 110001
BY ADVS.
B.PRAMOD
SHRI.B.PRAMOD, CGC,
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 7
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 3494 OF 2023
PETITIONER:
CHOVAKKARAN JOSEPH ELSY,AGED 66 YEARS
PROPRIETRIX, M/S. VELUR LUBRICANTS X11/226, VELUR
THRISSUR, PIN - 680601
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 ASSISTANT COMMISSIONER
GOODS & SERVICE TAX DEPARTMENT GOVERNMENT OFFICE
BUILDING VADAKKANCHERRY THRISSUR, PIN - 680582
2 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
GST POLICY WING, NORTH BLOCK, NEW DELHI, REPRESENTED BY
PRINCIPAL COMMISSIONER (GST)., PIN - 110001
3 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPT.,
GOVT. SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001
4 UNION OF INDIA
REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF
FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW
DELHI, PIN - 110001
BY ADV ADV. P.G. JAYASHANKAR PGJ
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 8
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 3557 OF 2023
PETITIONER:
CHOVAKKARAN JOSEPH ELSY,AGED 66 YEARS
PROPRIETRIX, M/S. VELUR LUBRICANTS X11/226, VELUR
THRISSUR, PIN - 680601
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 ASSISTANT COMMISSIONER
GOODS & SERVICE TAX DEPARTMENT GOVERNMENT OFFICE
BUILDING WADAKKANCHERRY THRISSUR, PIN - 680582
2 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
GST POLICY WING, NORTH BLOCK, NEW DELHI , REPRESENTED
BY PRINCIPAL COMMISSIONER (GST)., PIN - 110001
3 STATE OF KERALA,REPRESENTED BY SECRETARY TO GOVERNMENT,
TAXES DEPARTMENT, GOVT. SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
4 UNION OF INDIA,
REPRESENTED BY SECRETARY TO GOVERNMENT, MINISTRY OF
FINANCE (DEPARTMENT OF REVENUE), NORTH BLOCK, NEW
DELHI, PIN - 110001
BY ADV ADV. P.G. JAYASHANKAR PGJ
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 9
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 3922 OF 2023
PETITIONER:
CARMELIA HAVENS HOTELS AND RESORTS PRIVATE LIMITED
753/X, VANDANMEDU, NEDUMKANDAM UDUMBANCHOLA, IDUKKI,
KERALA., PIN - 685551
BY ADVS.
SABU C.J
RAHUL A.
JOY P.J.
APARNA ANIL
RESPONDENTS:
1 STATE TAX OFFICER
OFFICE OF THE JOINT COMMISSIONER, SGST DEPT, KERALA,
VANDIPERIYAR AT KUMILY., PIN - 685533
2 STATE OF KERALA
REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT
SECRETARIATE, THIRUVANANTHAPURAM., PIN - 695001
3 UNION OF INDIA,REPRESENTED BY THE SECRETARY, DEPARTMENT
OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NORTH BLOCK, NEW DELHI., PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 10
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 4186 OF 2023
PETITIONER:
SHABEER.T.M, (PROPEITOR),AGED 47 YEARS
M/S. T.M.AGENCIES, MANARY.P.O, PAIPRA, MUVATTUPUZHA.,
PIN - 686673
BY ADV P.N.DAMODARAN NAMBOODIRI
RESPONDENTS:
1 UNION OF INDIA
REPRESENTED BY ITS SECRETARY, MINISTRY OF FINANCE,
DEPARTMENT OF REVENUE, NEW DELHI., PIN - 110023
2 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, DEPARTMENT OF TAXES,
SECRETARIAT, THIRUVANANTHAPURAM ., PIN - 695001
3 COMMISSIONER,STATE GOODS AND SERVICE TAX DEPARTMENT,
9TH FLOOR, TAX TOWER, KILLIPALAM, KARAMANA PO. ,
THIRUVANANTHAPURAM ., PIN - 695001
4 STATE TAX OFFICER,
STATE GST DEPARTMENT, 2ND FLOOR, MINI CIVIL STATION,
KOTHAMANGALAM., PIN - 686691
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 11
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 4227 OF 2023
PETITIONER:
M/S. V.A. TREADS,13/862, NIDA, KANJIKODE WISE PARK
ROAD, PALAKKAD-678621, REPRESENTED BY ITS MANAGING
PARTNER, ANURUP.K., PIN - 678621
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 STATE TAX OFFICER,
STATE GOODS AND SERVICES TAX DEPARTMENT, THIRD CIRCLE,
PALAKKAD-678001., PIN - 678001
2 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS,GST POLICY
WING, NORTH BLOCK, NEW DELHI - 110 001, REPRESENTED BY
PRINCIPAL COMMISSIONER (GST)., PIN - 110001
3 STATE OF KERALA,REPRESENTED BY SECRETARY TO GOVERNMENT,
TAXES DEPT., GOVT. SECRETARIAT, THIRUVANANTHAPURAM, PIN
- 695001
4 UNION OF INDIA,REPRESENTED BY SECRETARY TO GOVERNMENT,
MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH
BLOCK, NEW DELHI, PIN - 110001
BY ADV P.T.DINESH
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 12
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 4495 OF 2023
PETITIONER:
MUHAMMED ABDUL SAINI,AGED 40 YEARS
PROPRIETOR, M/S. SALEEMS SUPER MARKET, MURIKKASSERY,
IDDUKKI, PIN - 685604
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 STATE TAX OFFICER,STATE GST DEPARTMENT, CHERUTHONI AT
IDDUKKI, PIN - 685609
2 UNION OF INDIA,REPRESENTED BY SECRETARY TO GOVERNMENT,
MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH
BLOCK, NEW DELHI, PIN - 110001
3 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
GST POLICY WING, NORTH BLOCK, NEW DELHI , REPRESENTED
BY PRINCIPAL COMMISSIONER (GST)., PIN - 110001
4 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPT.,
GOVT. SECRETARIAT, THIRUVANANTHAPURAM, PIN - 695001
BY ADV ADV. P.G. JAYASHANKAR PGJ
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 13
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 5690 OF 2023
PETITIONER:
AGRISOL IDUKKI PRIVATE LTD,
ROOM NO 15 529, NELLANICKAL BUILDING, PULIYANMALA,
KATTAPPANA, IDUKKI, KERALA REPRESENTED BY ITS DIRECTOR
ABDUL AZEEZ K.A, PIN - 685515
BY ADVS.
M.K.HAJARA
K.K.MOHINUDHEEN
AABID ALI K.
RESPONDENTS:
1 THE STATE TAX OFFICER ,STATE GOODS & SERVICES TAX
DEPARTMENT, KATTAPPANA, PIN - 685515
2 UNION OF INDIA,REPREENTED BY ITS SECRFTARY (REVENUN),
MINISTRYOF FINANCE, GOVERNMENT OF INDIA, NORTH BLOCK,
NEW DELHI -, PIN - 110001
3 THE CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
REPRESNETED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI, PIN - 110001
4 THE STATE OF KERALA
REPRESENTED BY ITS SECRETARY TO TAXES, SECRERARIAT,
THIRUVANANTHAPURAM -, PIN - 695001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 14
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 6134 OF 2023
PETITIONER:
MANGOMEADOWS AGRICULTURAL PLEASURE LAND PRIVATE LIMITED
XV/175A, AYAMKUDY, KADUTHURUTHY PANCHAYATH, KOTTAYAM.
REPRESENTED BY ITS MANAGING DIRECTOR, N. K. KURIAN, PIN
- 686613
BY ADVS.
SABU C.J
S.ANIL KUMAR (TRIVANDRUM)
RAHUL A.
APARNA ANIL
RESPONDENTS:
1 THE DEPUTY COMMISSIONER,STATE GOODS AND SERVICES TAX
DEPARTMENT, CIVIL STATION, KOTTAYAM., PIN - 686002
2 STATE OF KERALA
REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT
SECRETARIATE, THIRUVANANTHAPURAM., PIN - 695001
3 UNION OF INDIA,REPRESENTED BY THE SECRETARY, DEPARTMENT
OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NORTH BLOCK, NEW DELHI., PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 15
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 6776 OF 2023
PETITIONER:
JAISON GEEVARGHESE OOMMEN,AGED 48 YEARS
PROPRIETOR, M/S. ST. MARY'S CASHEW FACTORY, 163-166,
PUTHOOR, KOLLAM, PIN - 691507
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 THE ASSISTANT COMMISSIONER,AUDIT CIRCLE II, ST. MARY'S
BUILDING, KADAPPAKKADA, KOLLAM, PIN - 691008
2 UNION OF INDIA,REPRESENTED BY SECRETARY TO GOVERNMENT,
MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH
BLOCK, PIN - 110001
3 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
GST POLICY WING, NORTH BLOCK, NEW DELHI , REPRESENTED
BY PRINCIPAL COMMISSIONER (GST)., PIN - 110001
4 STATE OF KERALA
REPRESENTED BY SECRETARY TO GOVERNMENT, TAXES DEPT.,
GOVT. SECRETERIAT, THIRUVANANTHAPURAM, PIN - 695001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 16
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 7185 OF 2023
PETITIONER:
VARIKKOLIL RAHEEM,AGED 37 YEARS
PROPRIETOR, M/S. V.K. TRADERS, DOOR NO. XI - 214A,
KAPPUR, PALAKKAD, PIN - 679552
BY ADVS.
MEERA V.MENON
R.SREEJITH
K.KRISHNA
RESPONDENTS:
1 STATE TAX OFFICER,
STATE GOODS & SERVICES TAX DEPARTMENT, PATTAMBI,
PALAKKAD, PIN - 679303
2 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
GST POLICY WING, NORTH BLOCK, NEW DELHI, REPRESENTED BY
PRINCIPAL COMMISSIONER (GST)., PIN - 110001
3 STATE OF KERALA,REPRESENTED BY SECRETARY TO GOVERNMENT,
TAXES DEPARTMENT, GOVT. SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
4 UNION OF INDIA,REPRESENTED BY SECRETARY TO GOVERNMENT,
MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH
BLOCK, NEW DELHI, PIN - 110001
BY ADV ADV. P.G. JAYASHANKAR PGJ
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 17
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 7296 OF 2023
PETITIONER:
JS FUSION INDUSTRIES PRIVATE LIMITED
SIDCO, INDUSTRIAL ESTATE, KOTTAYAM. REPRESENTED BY ITS
CHIEF EXECUTIVE OFFICER AND DIRECTOR JOHN.T.A., PIN -
686631
BY ADVS.
SABU C.J
S.ANIL KUMAR (TRIVANDRUM)
RAHUL A.
APARNA ANIL
RESPONDENTS:
1 THE STATE TAX OFFICER,STATE GOODS AND SERVICES TAX
DEPARTMENT, MANGARAKALUNK, ETTUMANNUR P.O., PIN -
686631
2 STATE OF KERALA
REPRESENTED BY THE CHIEF SECRETARY, GOVERNMENT
SECRETARIATE, THIRUVANANTHAPURAM., PIN - 695001
3 UNION OF INDIA,REPRESENTED BY THE SECRETARY, DEPARTMENT
OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF INDIA,
NORTH BLOCK, NEW DELHI., PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 18
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 9238 OF 2023
PETITIONER:
METRO AGENCIES
764,765,766-1,766-2, HOSPITAL JUNCTION, NARAKKAL,
EMAKULAM DISTRICT, REPRESENTED BY ITS MANAGING PARTNER,
SABU JOSEPH KAVUNGAL, AGED 59 YEARS, S/O. JOSEPH
KAVUNGAL, PIN - 682505
BY ADVS.
R.MURALEEDHARAN
K.P.JOSE PIOUS
RESPONDENTS:
1 THE STATE TAX OFFICER-I
STATE GOODS AND SERVICES TAX DEPARTMENT, SECOND CIRCLE,
MATTANCHERRY, EMAKULAM DISTRICT ., PIN - 682002
2 THE JOINT COMMISSIONER OF STATE TAXES
STATE GOODS AND SERVICES TAX DEPARTMENT, MATTANCHERRY,
PIN - 682002
3 THE COMMISSIONER OF STATE TAXES
TAX TOWER, KILLIPALAM, KARAMANA P.O.,
THIRUVANATHAPURAM, PIN - 695002
4 STATE OF KERALA
REPRESENTED BY THE SECRETARY TO GOVERNMENT, TAXES
DEPARTMENT, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM,, PIN - 695001
5 UNION OF INDIA,REPRESENTED BY THE SECRETARY TO
GOVERNMENT, DEPARTMENT OF REVENUE, MINISTRY OF FINANCE,
GOVERNMENT OF INDIA, NEW DELHI., PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 19
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 9270 OF 2023
PETITIONER:
RAINBOW COLOUR HOUSE,6/907,ST. JOSEPH'S SHOPPING
COMPLEX KOTTAPADI, WAYANAD, REPRESENTED BY ITS
PROPRIETRESS SMT. REETHAMMA, PIN - 673577
BY ADVS.
K.S.HARIHARAN NAIR
HARIMA HARIHARAN
RAJATH R NATH
G.REMADEVI
GOPALAKRISHNAN NAIR P.N.
MOHANA KUMAR B.
RESPONDENTS:
1 STATE TAX OFFICER (LT)
STATE GOODS AND SERVICES TAX DEPARTMENT, WAYANAD,
ANAPPARA BUILDING, KALPETTA,, PIN - 673121
2 UNION OF INDIA,REPRESENTED BY SECRETARY, DEPARTMENT OF
REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI,
PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 20
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 9489 OF 2023
PETITIONER:
AMRUTHA TRADING CO.,
XV/365/1, HARI NAGAR, VITH STREET, PUNKUNAM, THRISSUR,
REPRESENTED BY ITS PROPRIETOR SRI. RAMACHANDRAN
ADHAMKAVIL, PIN - 680002
BY ADVS.
K.S.HARIHARAN NAIR
HARIMA HARIHARAN
RAJATH R NATH
G.REMADEVI
RESPONDENTS:
1 STATE TAX OFFICER
THIRD CIRCLE, STATE GOODS AND SERVICES TAX DEPARTMENT,
GST COMPLEX, POOTHOLE, THRISSUR, PIN - 680004
2 UNION OF INDIA,REPRESENTED BY SECRETARY, DEPARTMENT OF
REVENUE, MINISTRY OF FINANCE, NORTH BLOCK, NEW DELHI,
PIN - 110001
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 21
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 10481 OF 2023
PETITIONER:
M/S P.K CONSTRUCTIONS CO,
XV/145, POTTAIKANDATHILNEAR NGO QUATERS MUVATTUPUZHA
P.O., ERNAKULAM-686661 REPRESENTED DY ITS MANAGING
PARTNER KABEER KHAN POTTAIKANDATHIL BAVA RAWTHER
BY ADV DIVYA RAVINDRAN
RESPONDENTS:
1 THE STATE TAX OFFICER-II,
OFFICE OF STATE TAX OFFICER,MINI CIVIL STATION.
MUVATTUPUZHA, MUDAVOOR P.O., ERNAKULAM - 686669
2 CENTRAL BOARD OF INDIRECT TAXES,
GST POLICY WING, NORTH BLOCK, NOW DELHI-110001
REPRESENTED BY PRINCIPAL COMMISSIONER
3 STATE OF KERALA,TAXES DEPARTMENT, GOVT. SECRETARIAT,
TRIVANDRUM - 695001 REPRESENTED BY SECRETARY TO
GOVERNMENT, PIN - 695001
SRI. MUHAMED RAFIQ-SPL.GP
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 22
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 10663 OF 2023
PETITIONER:
AMRUTHA TRADING CO.,XV/365/1, HARI NAGAR, VITH STREET,
PUNKUNAM, THRISSUR, 680002 REPRESENTED BY ITS
PROPRIETOR SRI. RAMACHANDRAN ADHAMKAVIL
BY ADVS.
K.S.HARIHARAN NAIR
HARIMA HARIHARAN
RAJATH R NATH
G.REMADEVI
RESPONDENTS:
1 STATE TAX OFFICER,
THIRD CIRCLE, STATE GOODS AND SERVICES TAX DEPARTMENT,
GST COMPLEX, POOTHOLE, THRISSUR, PIN - 680004
2 UNION OF INDIA,
REPRESENTED BY ITS SECRETARY (REVENUE), MINISTRY OF
FINANCE, NORTH BLOCK, NEW DELHI, PIN - 110001
3 CENTRAL BOARD OF INDIRECT TAXES AND CUSTOMS,
REPRESENTED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI, PIN - 110001
4 STATE OF KERALA
REPRESENTED BY ITS SECRETARY TO TAXES, SECRETARIAT,
THIRUVANANTHAPURAM, PIN - 695001
BY ADV M.S.AMAL DHARSAN
SRI. MUHAMED RAFIQ-SPL.GP
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 23
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 13068 OF 2023
PETITIONER:
JOY JOSEPH, PROPRIETOR,AGED 53 YEARS
ANNA SWEET HOUSE, VALIYATH BUILDING, ATHIRAMPUZHA,
KOTTAYAM, PIN - 686562
BY ADV V.DEVANANDA NARASIMHAM
RESPONDENTS:
1 STATE TAX OFFICER, KSGST DEPARTMENT, MANGARAKALUNK,
ETTUMANOOR P.O, KOTTAYAM, PIN - 686631
2 STATE OF KERALA, REPRESENTED BY ITS SECRETARY
DEPARTMENT OF TAXES, SECRETARIAT, THIRUVANANTHAPURAM,
PIN - 695001
3 UNION OF INDIA, REPRESENTED BY ITS SECRETARY
MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, NEW DELHI,
PIN - 110023
SRI. MUHAMED RAFIQ-SPL.GP
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 24
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 13976 OF 2023
PETITIONER:
BPL TELECOM PVT. LTD.,
SYSTEM HOUSE, KOOTTUPATHA, CHANDRANAGAR POST, PALAKKAD-
678007 REPRESENTED BY ITS AUTHORISED SIGNATORY - MR.
VEERARAGHAVAN R.V.
BY ADVS.
RAJA KANNAN
M.GOPIKRISHNAN NAMBIAR
K.JOHN MATHAI
JOSON MANAVALAN
KURYAN THOMAS
PAULOSE C. ABRAHAM
RESPONDENTS:
1 UNION OF INDIA,REPRESENTED BY SECRETARY TO GOVERNMENT,
MINISTRY OF FINANCE (DEPARTMENT OF REVENUE), NORTH
BLOCK, NEW DELHI -110001
2 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS,
GST POLICY WING, NORTH BLOCK, NEW DELHI,REPRESENTED BY
PRINCIPAL COMMISSIONER (GST) -110001
3 STATE OF KERALA,REPRESENTED BY SECRETARY TO GOVERNMENT,
TAXES DEPARTMENT, GOVERNMENT SECRETARIAT,
THIRUVANANTHAPURAM -695001
4 THE DEPUTY COMMISSIONER (ASSESSMENT), SPECIAL CIRCLE
STATE GOODS AND SERVICES TAX DEPARTMENT, GST COMPLEX,
BEHIND CIVIL STATION, PALAKKAD, PIN - 678001
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 25
IN THE HIGH COURT OF KERALA AT ERNAKULAM
PRESENT
THE HONOURABLE MR. JUSTICE DINESH KUMAR SINGH
WEDNESDAY, THE 12TH DAY OF JUNE 2024 / 22ND JYAISHTA, 1946
WP(C) NO. 14193 OF 2023
PETITIONER:
BLISS WORLDWIDE DESTINATION MANAGEMENT PRIVATE LIMITED
1ST FLOOR, 164, JAWAHAR NAGAR, KADAVANTHRA, KOCHI.
REPRESENTED BY ITS. AUTHORISED SIGNATORY SRI. SIJO
JOSEPH., PIN - 682020
BY ADVS.
RAHUL A.
SABU C.J
M.RAJAGOPAL
APARNA ANIL
RESPONDENTS:
1 THE STATE TAX OFFICER
STATE GOODS AND SERVICE TAX DEPARTMENT, 2ND CIRCLE,
TRIPUNITHURA, ERNAKULAM DISTRICT., PIN - 682303
2 UNION OF INDIA,REPRESENTED BY THE SECRETARY, DEPARTMENT
OF REVENUE, MINISTRY OF FINANCE, GOVERNMENT OF
INDIA,NORTH BLOCK, NEW DELHI., PIN - 110001
3 CENTRAL BOARD OF INDIRECT TAXES & CUSTOMS
REPRESENTED BY ITS CHAIRMAN, DEPARTMENT OF REVENUE,
NORTH BLOCK, NEW DELHI., PIN - 110001
4 STATE OF KERALA
REPRESENTED BY ITS SECRETARY, TAXES DEPARTMENT,
SECRETARIAT, THIRUVANANTHAPURAM., PIN - 695001
BY ADV M.S.AMAL DHARSAN
SRI. MUHAMED RAFIQ-SPL.GP
SRI P.R.SREEJITH, SC, GSTN
SRI SREELAL N.WARRIER, SC, CENTRAL BOARD OF EXCISE
THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON
12.06.2024, ALONG WITH WP(C).286/2023 AND CONNECTED CASES, THE
COURT ON THE SAME DAY DELIVERED THE FOLLOWING:
WPC No.286 of 2023 & conn.cases 26
JUDGMENT
[WP(C) Nos.286/2023, 906/2023, 1412/2023, 1977/2023, 2070/2023,
2735/2023, 3494/2023, 3557/2023, 3922/2023, 4186/2023, 4227/2023,
4495/2023, 5690/2023, 6134/2023, 6776/2023, 7185/2023, 7296/2023,
9238/2023, 9270/2023, 9489/2023, 10481/2023, 10663/2023,
13068/2023, 13976/2023, 14193/2023]
This batch of writ petitions contains three sets of cases. In
some cases, the respective supplier had remitted the tax (GST) but
not reflected in their return GSTR due to some technical reasons.
Another set of petitioners are those who have received the goods
or services and have valid tax invoices, proof of payment of the
value of goods along with the GST component to the respective
suppliers, but the respective suppliers had not remitted the GST
on the supply made by them to the petitioners. The third set of
petitioners are those who are in possession of the invoice but
have no clear proof of payment of consideration and tax towards
the inward supply and might not have received goods in their
possession. Common questions of facts and law are involved in
these writ petitions. W.P.(C) Nos.31559/2019 and connected
matters were disposed on 4.6.2024 by this Court and the
controversy has been decided by judgment of even date.
2. The same points arise in the instant batch of writ
petitions. The operative portion of the judgment in WPC
No.31559 of 2019 dated 4.6.2024 reads as follows:
"99. The Government had realized the difficulty in the initial roll out
of the GST regime under the CGST/SGST Act and considered that
GSTR 2A was not available initially in the Finance years 2017-2018
and 2018-2019 during the implementation of GST. In order to resolve
all bona fide claims and mistakes, Circular No.183/15/2022- GST dated
27.12.2022 and Circular No. 193/05/2023- GST dated 17.07.2023 have
been issued. Circulars cover the period from the introduction of GST
till Section 16(2) (aa) was introduced with effect from 01.01.2022. The
ITC can be availed by the recipient for the bona fide scenarios listed
in those Circulars on submitting proof of payment to the Government
by the supplier. Therefore, if, during the pendency of these writ
petitions, the petitioners who could have got the benefits of these
Circulars and could not avail the benefits within the time limit
prescribed, may approach the appropriate GST authority within a
period of thirty days from today to avail the benefit of the aforesaid
Circulars, if the same is/are applicable to their case. The GST
authorities will examine the claim of the individual dealer by
applying the provisions of the Circulars, and it will grant applicable
relief to eligible dealers.
100. Prior to the amendment in Section 39 by the Finance
Act 2022, the date for furnishing the return under Section 39 was
30th September. Considering the difficulties in the initial stage of
the implementation of the GST regime, its understanding, and
compliance, the Legislature effected the amendment and extended
the time for filing the return for September to 30th November in
each succeeding Financial Year. The amendment is only procedural
to ease the difficulties initially faced by the dealers / taxpayers.
Therefore, where for the period from 01.07.2017 till 30.11.2022, if a
dealer has filed the return after 30th September and the claim for
ITC was made before 30th November, the claim for ITC of such
dealer should also be processed if he is otherwise entitled to claim
the ITC. It has been pointed out in several cases which are pending
before this Court that the claim was made before 30th November of
the succeeding Financial Year, but the relevant period was 20th
October, which was the extended date for furnishing the return
under Section 39 for the month of September. Therefore, if a person
has furnished the return for the month of September till 30th
November, their claim should also be considered and processed and
should not be rejected if the dealer did not furnish the return for the
month of September on or before 20th October. This amendment
being procedural has to be given retrospective effect and, therefore,
it is provided that it should be treated that the time limit for
furnishing the return for the month of September is 30th November
in each Financial Year with effect from 01.07.2017, considering the
peculiar nature of difficulties in the initial period of implementation
of the GST regime. So far as the challenge to the constitutional
validity of Section 16(2)(c) and Section 16(4) is concerned, the same
is rejected.
Result:
101. The liberty is granted to the petitioners, who can
claim the benefit of the two Circulars, namely, Circular No.
183/15/2022- GST dated 27.12.2022 and Circular No. 193/05/2023-
GST dated 17.07.2023 to make their claim within one month from
today before the appropriate authority who shall examine the claim
of the individual dealer and process the claim.
101.1 The time limit for furnishing the return for the
month of September is to be treated as 30 th November in each
financial year with effect from 01.07.2017, in respect of the
petitioners who had filed their returns for the month of September
on or before 30th November, and their claim for ITC should be
processed, if they are otherwise eligible for ITC."
Hence, by adopting the reasoning, observations and
conclusions recorded in the judgment dated 04.06.2024 in W.P.(C)
Nos.31559/2019 and connected matters, these writ petitions stand
disposed of.
All Interlocutory Applications regarding interim matters stand
closed.
sd/-DINESH KUMAR SINGH, JUDGE
css/
APPENDIX OF WP(C) 906/2023
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE UNDER SECTION 73(1)
PASSED FOR THE YEAR 2017-18 DATED: 03.11.2022
Exhibit P2 A TRUE COPY OF THE SUMMERY OF THE SHOW CAUSE
NOTICE ISSUED U/S.73 DATED: 03.11.2022.
Exhibit P2(a) A TRUE COPY OF THE SUMMERY OF THE SHOW CAUSE
NOTICE IN FORM GST DRC-01 FOR 2017-18 DATED:
03.11.2022
Exhibit P3 A TRUE COPY OF THE PROCEEDINGS PASSED FOR THE
YEAR 2017-18 DATED: 13.12.2022
Exhibit P3(a) A TRUE COPY OF THE ORDER DATED: 13.12.2022
ISSUED ALONG WITH EXT.P.3
Exhibit P3(b) A TRUE COPY OF THE SUMMARY OF THE ORDER
ISSUED IN FORM GST DRC-07 FOR 2017-18 DATED:
13.12.2022
APPENDIX OF WP(C) 1412/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDINGS PASSED U/S. 73
OF THE GST ACTS FOR 2017-18 DATED: 25.10.2022
Exhibit P1(a) TRUE COPY OF THE SUMMERY OF ORDER U/S. 73 OF
THE GST ACTS FOR 2017-10 DATED: 25.10.2022
Exhibit P1(b) TRUE COPY OF THE ORDER/RECOVERY NOTICE ISSUED
IN FORM GST DRC-07 FOR 2017-28 DATED:
25.10.2022
APPENDIX OF WP(C) 1977/2023
PETITIONER EXHIBITS
Exhibit-P1 TRUE COPY OF ANNUAL RETURN FILED BY THE
PETITIONER IN FORM GSTR-9 ONLINE ON 04-02-20
FOR 2017-18 THROUGH GSTN MODULE BEFORE 1ST
RESPONDENT.
Exhibit-P2 TRUE COPY OF GST ASMT-10 NOTICE DATED 06-07-
20 ISSUED U/S 61 OF THE GST ACTS FOR 2017-18
BY THE 1ST RESPONDENT TO THE PETITIONER.
Exhibit-P3 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED U/S
73 (1) AND GST DRC-01 OF THE GST ACTS DATED
01-07-21 FOR 2017-18 BY 1ST RESPONDENT ON THE
PETITIONER.
Exhibit-P4 TRUE COPY OF THE REPLY FILED TO EXBT-P3 SHOW
CAUSE NOTICE IN FORM GST DRC-06 DATED 18-09-
Exhibit-P5 TRUE COPY OF THE ASSESSMENT ORDER PASSED U/S
73 OF THE GST ACTS ON 13-09-22 AND FORM GST
DRC-07 SUMMARY ORDER UNDER RULE 142(5) OF THE
GST RULES ALONG WITH DEMAND NOTICE ISSUED BY
1ST RESPONDENT FOR THE YEAR 2017-18 .
APPENDIX OF WP(C) 2070/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE PROCEEDINGS PASSED U/S. 73
OF THE GST ACTS FOR 2018-19 DATED: 17.11.2022
Exhibit P1(a) TRUE COPY OF THE ORDER U/S. 73 OF THE GST
ACTS FOR 2018-19 DATED: 17.11.2022
Exhibit P1(b) TRUE COPY OF THE SUMMERY OF THE
ORDER/RECOVERY NOTICE ISSUED IN FORM GST DRC-
07 FOR 2018-19 DATED: 17.11.2022
APPENDIX OF WP(C) 2735/2023
PETITIONER EXHIBITS
Exhibit1 COPY OF SHOW CAUSE NOTICE DATED 17-12-2022
ISSUED BY THE 1ST RESPONDENT
Exhibit P2 COPY OF THE INTERIM ORDER IN WP(C) NO.
10824/2022 DATED 29-03-2022 PASSED BY THE
HON'BLE HIGH COURT OF KERALA
APPENDIX OF WP(C) 3494/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ORDER ISSUED BY THE 1ST RESPONDENT
FOR THE YEAR 2018-19 DTD. 07-10-2022
Exhibit P2 COPY OF ORDER IN WPC NO. 29479/22 OF THIS
HON'BLE COURT DTD. 16-09-2022
APPENDIX OF WP(C) 3557/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ORDER ISSUED BY THE 1ST RESPONDENT
FOR THE YEAR 2019-20 DTD. 07-10-2022
Exhibit P2 COPY OF ORDER IN WPC NO. 29479/22 OF THIS
HON'BLE COURT DTD, 16-09-2022
APPENDIX OF WP(C) 3922/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTIFICATION NO. 52/2020 - CENTRAL
TAX DATED 24-06-2020ISSUED BY THE 2ND
RESPONDENT
Exhibit P2 COPY OF NOTIFICATION NO. 19/2021- CENTRAL TAX
DATED 01-06-2021ISSUED BY THE 2ND RESPONDENT
Exhibit P3 COPY OF NOTIFICATION NO. 33/2021- CENTRAL TAX
DATED 29-08-2021 ISSUED BY THE 2ND RESPONDENT
Exhibit P4 A COPY OF THE SHOW CAUSE NOTICE DATED 29-10-
2022 ISSUED BY THE 1ST RESPONDENT FOR THE
PERIOD OCTOBER, 2018 TO MARCH, 2019.
Exhibit P5 A COPY OF THE SHOW CAUSE NOTICE DATED 14-11-
2022 ISSUED BY THE 1ST RESPONDENT FOR THE
PERIOD FROM NOVEMBER, 2019 TO MARCH, 2020.
Exhibit P6 COPY OF THE INTERIM ORDER IN WP(C) NO.
10824/2022 DATED 29-03-2022 PASSED BY THE
HON'BLE HIGH COURT OF KERALA
APPENDIX OF WP(C) 4186/2023
PETITIONER EXHIBITS
Exhibit- P1 TRUE COPY OF THE NOTICE IN FORM GST ASMT-10
REFERENCE NO.32CJGPM9092M IZM/ 01 /2017-18
DATED 03.07.2020 ISSUED U/S.61 OF THE ACT,
2017 BY THE 4TH RESPONDENT.
Exhibit-P2 TRUE COPY OF THE REPLY IN FORM GST ASMT-11
DATED 01.08.2020
Exhibit- P3 TRUE COPY OF THE SHOW CAUSE NOTICE REFERENCE
NO.32CJGPM9092M 1 ZM / DRCO 1 SCN /2017-18/01
DATED 22.07.2021 IN FORM GST DRC-01 ISSUED BY
THE 4TH RESPONDENT
Exhibit- P 4 TRUE COPY OF THE REPLY IN FORM GST DRC-06
DATED 31.12.2021 SUBMITTED BEFORE THE 4TH
RESPONDENT.
Exhibit -P 5 TRUE COPY OF THE ORDER UNDER SECTION 73 OF
THE ACT ALONG WITH DRC-07
NO.32CJGPM9092MIZM /2017-18/ 13 DATED
20.08.2022 FOR THE PERIOD OF 07/2017 TO
03/2018 TO THE PETITIONER
Exhibit- P 6 TRUE COPY OF THE CIRCULAR BEARING
NO.123/42/2019-GST DATED 11.11.2019 ISSUED BY
THE MINISTRY OF FINANCE, GOVERNMENT OF INDIA.
Exhibit- P 7 TRUE COPY OF CIRCULAR NO.122/41/2019 -GST
DATED 05.11.2019 ISSUED BY THE CENTRAL BOARD
OF DIRECT TAXES AND CUSTOMS.
Exhibit- P 8 TRUE COPY OF THE CIRCULAR NO.8/2020, (FILE
NO.CT/4132/2020-CB) DATED 04.08.2020 ISSUED
BY COMMISSIONER OF STATE TAX.
Exhibit- P 9 TRUE COPY OF THE PRESS RELEASE DATED
04.05.2018 ISSUED BY THE CBIC.
Exhibit- P 10 TRUE COPY OF THE PRESS RELEASE DATED
18.10.2018 ISSUED BY THE CBIC.
Exhibit- P11 TRUE COPY OF THE INTERIM ORDER IN W.P.
(C).NO.1650/2023 DATED 23.01.2023 OF THE
HONOURABLE HIGH COURT, AT ERNAKULAM.
APPENDIX OF WP(C) 4227/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTICE IN FORM GST ASMT 10 ISSUED BY
THE 1ST RESPONDENT DTD. 15-10-2022
Exhibit P2 COPY OF ORDER IN WPC NO. 29479/22 OF THIS
HON'BLE COURT DTD. 16-09-2022
APPENDIX OF WP(C) 4495/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ASSESSMENT ORDER ISSUED BY THE 1ST
RESPONDENT DTD. 06-07-2022
Exhibit P2 COPY OF ORDER IN WPC NO. 34128/2022 OF THIS
HON'BLE COURT DTD. 28-10-2022
APPENDIX OF WP(C) 5690/2023
PETITIONER EXHIBITS
Exhibit P1 A TRUE COPY OF THE NOTICE SO ISSUED IN FORM
GST ASMT 10 PERTAINING TO THE YEAR 2019-20
DATED: 25.08.2022
Exhibit P2 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED U/S
73(1)DATED 27.10.2022
Exhibit P3 THE TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED
U/S.73 DATED 28.10.2022
Exhibit P3(a) THE TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED
U/S.73 SUMMARY OF SHOW CAUSE NOTICE IN FORM
GST DRC -01 DATED 28.10.2022
APPENDIX OF WP(C) 6134/2023
PETITIONER EXHIBITS
Exhibit P1 A COPY OF NOTIFICATION NO. 52/2020 - CENTRAL
TAX DATED 24-06-2020 ISSUED BY THE 3RD
RESPONDENT.
Exhibit P2 A COPY OF NOTIFICATION NO. 19/2021- CENTRAL
TAX DATED 01-06-2021 ISSUED BY THE 3RD
RESPONDENT
Exhibit P3 A COPY OF NOTIFICATION NO. 33/2021- CENTRAL
TAX DATED 29-08-2021 ISSUED BY THE 3RD
RESPONDENT
Exhibit P4 A COPY OF THE ORDER DATED 20/12/2022 ISSUED
BY THE 1ST RESPONDENT U/S73 OF THE CGST/SGST
ACT FOR THE YEAR 2018-19.
Exhibit P5 A COPY OF THE ORDER DATED 20/12/2022 ISSUED
BY THE 1ST RESPONDENT U/S 73 OF THE CGST/SGST
ACT FOR THE YEAR 2019-20
Exhibit P6 COPY OF THE INTERIM ORDER IN WP(C) NO.
10824/2022 DATED 29-03-2022 PASSED BY THE
HON'BLE HIGH COURT OF KERALA
APPENDIX OF WP(C) 6776/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF SHOW CAUSE NOTICE ISSUED BY THE 1ST
RESPONDENT DTD. 02-02-2023
Exhibit P2 COPY OF ORDER IN WPC NO. 31157/2022 OF THIS
HON'BLE COURT DTD. 30-09-2022
APPENDIX OF WP(C) 7185/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ORDER IN FORM GST DRC-07 ALONG WITH
ITS SUMMARY AND ANNEXUYRE ISSUED BY THE 1ST
RESPONDENT DTD. 12-12-2022
Exhibit P2 COPY OF ORDER IN WPC NO. 32854/2022 OF THIS
HON'BLE COURT DTD. 18-10-2022
APPENDIX OF WP(C) 7296/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF NOTIFICATION NO. 52/2020 - CENTRAL
TAX DATED 24-06-2020 ISSUED BY THE 3RD
RESPONDENT
Exhibit P2 COPY OF NOTIFICATION NO. 19/2021- CENTRAL TAX
DATED 01-06-2021ISSUED BY THE 3RD RESPONDENT
Exhibit P3 COPY OF NOTIFICATION NO. 33/2021- CENTRAL TAX
DATED 29-08-2021ISSUED BY THE 3RD RESPONDENT
Exhibit P4 A COPY OF THE SHOW CAUSE NOTICE DATED 20-09-
2022 ISSUED BY THE 1ST RESPONDENT U/S73 (1)
OF THE CGST/SGST ACT
Exhibit P5 COPY OF THE INTERIM ORDER IN WP(C) NO.
10824/2022 DATED 29-03-2022 PASSED BY THE
HON'BLE HIGH COURT OF KERALA
APPENDIX OF WP(C) 9238/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE ISSUED BY THE LST
RESPONDENT INTIMATING DISCREPANCIES IN
RETURN, DATED 22.09.2020
Exhibit P2 TRUE COPY OF THE REPLY FILED BY THE
PETITIONER IN FORM GST ASMT-11 DATED
03.04.2021
Exhibit P3 TRUE COPY OF THE REMIND NOTICE ISSUED BY THE
LST RESPONDENT, DATED 27.12.2021
Exhibit P4 TRUE COPY OF THE DETAILED OBJECTIONS FILED BY
THE PETITIONER DATED 21.01.2022
Exhibit P5 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED BY
THE 1 ST RESPONDENT DATED 25.01.2022
Exhibit P6 TRUE COPY OF THE REPLY TO SHOW CAUSE NOTICE
FILED BY THE PETITIONER DATED 19.02.2022
Exhibit P7 TRUE COPYTHE ASSESSMENT ORDERPASSED BYTHE LST
RESPONDENT UNDER S.73(1) OF THE SGST/CGST
ACT, 2017, DATED.24.10.2022
APPENDIX OF WP(C) 9270/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF FORM GSTR 3B RETURN DATED 27-11-2020
FILED BY THE PETITIONER FOR THE MONTH MARCH
Exhibit P2 COPY OF NOTIFICATION NO. 19/2021 DATED 1-06-
2021 ISSUED BY THE 2ND RESPONDENT
Exhibit P3 COPY OF NOTIFICATION NO. 33/2021 DATED 29-08-
2021 ISSUED BY THE 2ND RESPONDENT
Exhibit P4 COPY OF NOTICE IN FORM ASMT-10 DATED 23-05-
2022 ISSUED BY THE 1ST RESPONDENT
Exhibit5 COPY OF THE REPLY DATED 01-11-2022 SUBMITTED
BY THE PETITIONER
Exhibit P6 COPY OF THE SHOW-CAUSE NOTICE DATED 08-11-
2022 ISSUED BY THE 1ST RESPONDENT
Exhibit P7 COPY OF THE REPLY DATED 29-11-2022 SUBMITTED
BY THE PETITIONER
Exhibit P8 COPY OF THE ORDER DATED 27-12-2022 ISSUED BY
THE 1ST RESPONDENT
Exhibit P9 COPY OF THE AUDITED TRADING, PROFIT AND LOSS
ACCOUNT AND BALANCE SHEET OF THE PETITIONER
FOR THE FINANCIAL YEAR 2019-20 DATED 27-03-
APPENDIX OF WP(C) 9489/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF SHOW CAUSE NOTICE IN FORM GST DRC 01
DATED 09-12-2022 ISSUED BY THE 1ST RESPONDENT
Exhibit P2 COPY OF THE ORDER DATED 11-01-2023 ISSUED BY
THE 1ST RESPONDENT
APPENDIX OF WP(C) 10481/2023
PETITIONER EXHIBITS
Exhibit P1 TRUE COPY OF THE NOTICE U/S 71(1) CGST ACT.
2017, ISSUED BY THE 1ST RESPONDENT DATED
25.2.2022,
Exhibit P2 TRUE COPY OF THE REPLY FILED BY THE
PETITIONER DATED 25.3.2022
Exhibit P3 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED U/S
73(1) OF KGST/CGST ACT, 2017 DATED
30.08.2022,
Exhibit P4 TRUE COPY OF THE PROCEEDINGS ISSUED BY THE
1ST RESPONDENT U/S 73 R.W.R 142 OF THE
KGST/GST ACT DATED 30.09.2022 IN ORDER NO -
32AALEFP2363G1ZD/2017-18
Exhibit P5 TRUE COPY OF THE RETURNS FILED BY THE
PETITIONER IN GSTR- 38 AS PROVIDED UNDER RULE
61 (® OF THE GST RULES WITH RESPECT TO THE
MONTHS OF JULY 2017 TO FEBRUARY 2018, ON
29.4.2019.
APPENDIX OF WP(C) 10663/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF THE SHOW-CAUSE NOTICE DATED 25-02-
2022 ISSUED BY THE 1ST RESPONDENT
Exhibit P2 COPY OF THE REPLY DATED 20-03-2022 SUBMITTED
BY THE PETITIONER
Exhibit P3 COPY OF THE ORDER DATED 16-08-2022 ISSUED BY
THE 1ST RESPONDENT
Exhibit P4 COPY OF THE RECTIFICATION PETITION DATED 11-
03-2023 SUBMITTED BY THE PETITIONER
APPENDIX OF WP(C) 13068/2023
PETITIONER EXHIBITS
Exhibit-P1 TRUE COPY OF ANNUAL RETURN FILED BY THE
PETITIONER IN FORM GSTR-9 ONLINE ON 26-08-19
FOR 2017-18 THROUGH GSTN MODULE BEFORE 1ST
RESPONDENT.
Exhibit-P2 TRUE COPY OF GST ASMT-10 NOTICE DATED 16-07-
20 ISSUED U/S 61 OF THE GST ACTS FOR 2017-18
BY THE 1ST RESPONDENT TO THE PETITIONER.
Exhibit-P3 TRUE COPY OF REPLY DATED 16-08-20 AGAINST
EXBT-P2 NOTICE FILED FOR THE YEAR 2017-18.
Exhibit-P4 TRUE COPY OF THE SHOW CAUSE NOTICE ISSUED U/S
73 (5) OF THE GST ACTS DATED 04-10-21 FOR THE
YEAR 2017-18 BY 1ST RESPONDENT ON THE
PETITIONER.
Exhibit-P5 TRUE COPY OF THE REPLY DATED 19-10-21 AGAINST
EXBT-P4 SHOW CAUSE NOTICE FILED BY THE
PETITIONER BEFORE 1ST RESPONDENT.
Exhibit-P6 TRUE COPY OF THE ASSESSMENT ORDER PASSED U/S
73(9) OF THE GST ACTS DATED 15-07-22 AND FORM
GST DRC-07 DEMAND NOTICE UNDER RULE 142(5) OF
THE GST RULES PASSED BY 1ST RESPONDENT FOR
THE YEAR 2017-18.
APPENDIX OF WP(C) 13976/2023
PETITIONER EXHIBITS
Exhibit P1 THE TRUE COPY OF THE ORDER OF ASSESSMENT
DATED 05.01.2023 ISSUED BY THE 4TH RESPONDENT
FOR THE YEAR 2017-18
Exhibit P2 THE TRUE COPY OF THE SUMMARY ORDER OF
ASSESSMENT IN FORM-GST DRC-07 DATED
05.01.2023, ISSUED BY THE 4TH RESPONDENT
ALONG WITH EXT. P1 ORDER
APPENDIX OF WP(C) 14193/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ORDER DATED 20-12-2022 ISSUED BY THE
1ST RESPONDENT FOR THE YEAR 2017-2018.
Exhibit P1(a) COPY OF ORDER DATED 21-12-2022 ISSUED BY THE
1ST RESPONDENT U/S.73 OF THE CGST/SGST ACT
AND SUMMARY OF THE ORDER ISSUED BY THE 1ST
RESPONDENT IN FORM GST DRC-07.
Exhibit P2 COPY OF THE INTERIM ORDER IN WP(C)
NO.1604/2023 DATED 18-01-2023 PASSED BY THIS
HON'BLE COURT.
APPENDIX OF WP(C) 286/2023
PETITIONER EXHIBITS
Exhibit P1 COPY OF ASSESSMENT ORDER ISSUED BY THE 1ST
RESPONDENT DTD. 11-02-2022
Exhibit P2 COPY OF APPEAL FILED BY THE PETITIONER BEFORE
THE 2ND RESPONDNENT DTD. 04-06-2022
Exhibit P3 COPY OF APPELLATE ORDER ISSUED BY THE 2ND
RESPONDENT DTD. 30-09-2022
Exhibit P4 COPY OF ORDER IN WPC NO. 35979/2022 OF THIS
HON'BLE COURT DTD. 10-11-2022
