M/S . Seven Star Mining Agencies LLP vs. The Assistant Commissioner Of Central Tax

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WP/17892/2026HC TelanganaGSTCNR HBHC01033403202615 June 2026Bench: APARESH KUMAR SINGH,G.M. MOHIUDDIN8 pages
For Petitioner: SRI P.VENKAT PRASAD FOR M/s P.V.PRASAD, ASSOCIATESFor Respondent: SR! DOMINIC FERNANDES, SENTOR, STANDING COUNSEL FOR CBIC

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Cause title — parties, addresses and appearances
[ 3488 I IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) NNONDAY, THE FIFTEENTH DAY OT .IU,TTTE TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE THE CHIEF JUSTICE SRIAPARESH KUMAR SINGH AND THE HONOI."IRABL.E $RI JU$TICE G.M. MOHIUDDIN Between I M/s . Seven Star Mining Agencies LLP, SY No.277 to 285, Plot No. 328 and 333, Lalanguda, Rampally, Rangareddy, Telangana 501 301 Represented by its Authorised Signatory Jay Prakash Kumar S/o. Bir Bahadur Singh, Aged about 24 years, Bir Bahadur Singh, Village, Bhartadih Post Kirhi, Rohtas, Gorari, Bihar- 802214, ...PETITIONER AND 1. The Assistant Commissioner of Central tax, Medchal Division, Medchal Commissionerate, Aditya Towers, Sri Sai Enclave, Old Bowenpally, Secunderabad; Telangana 500 011 2. The Assistant Commissioner of Central tax, Karimnagar Division, 2nd Floor, H.No.8-7-29611, Manikanta Complex, Hanuman Nagar, Karimnagar, Telangana 505 001 3. Additional Commissioner of Central Tax, Hyderabad Audit-ll ' Commissionerate, Sanvi Yamuna Pride, 1-98/B Plot 20 and 21, VIP Hills, Madhapur, Telangana - 500 081 4. Joint Commissioner of Central tax, Medchal Commissionerate, 11-4-64918, Lakdikapul, Hyderabad, Telangana 500 004. 5. The Union of lndia, represented by the Secretary, Ministry of Finance, Department of Revenue, North Block, New Delhi 110 001 6. W G Enterprises Private Limited, SSI PLOT NO.21A, NH-s, N.l.T., Faridabad, Haryana, 121001 Represented by its authorised signatory 7. M/s. Bafna Earthmovers, Shop no 111, Manik Moti complex, SR no 83/84 katraj, Pune, Maharashtra 411 046 Represented by its Proprietor, Shri. Vinit Rameshbhai Shah 8. M/s. R.K. Enterprises Earth Moving Spares, Sy No.254, Plot No.1/A, Dommarapochampally Village, 3-8912, Dundigal Gandimaisamma Mandal, Quthbullapur, Telangana 500 043 Represented by its Partner N ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybepleased to issue a writ, order, or direction more particularly one in the nature of writ of mandamus declaring tt a) The Provisions of Section 16(2Xc) of the CGST Acl' 2017 as well as Section 16(2Xc) of the TGST Acl, 2017 as arbitrary, without jurisdiction, unconstitutional, against the principles of natural justice and as ultra-vires to the provisions of Article 14, 30OA and Article 19(1 Xg) of the Constitution of lndia' b)Theorder-in-origirra|No'110/2023dated01.02.2024readwithFormDRC-07 bearing 2D3602240104131 dated 07.02.2024 as being void, arbitrary, illegal, without jurisdiction, without authority of law apart from being violative of Articles 14, 19(1Xg) and 265 of the Constitution of lndia, and to consequently set aside the same c)RecoverynoticesinFormGSTDRc13dated10.04.2026issuedto Respondent Nos. 6 to 7 as being void, arbitrary, illegal, without jurisdiction, without authority of law apart from being violative of Articles 14' 19(1Xg) and 265 of the Constitution of lndia, and to consequently set aside the same d)RecoverynoticesinFormGSTDRc13dated30.09.2025videC.No. vto1lo4t2o24 issued to the Respondent no. I as being void, arbitrary, illegal, without jurisdiction, without authority of law apart from being violative of Articles 14, 19(1Xg) and 265 of the constitution of lndia, and to consequently set aside the same. 1 Petition under Section 1 51 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to stay Garnishee Notice in Form GST DRC 13 dated 30.09.2025 vide Ref No. VtO1tO4t2O24 under section 7S (1)(c) of the CGST Ad'2017 ' 20F Petition under section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to stay Order- in-originat No. 1 10/2023 vide Ref No.c.No vl15l8ol2023-24 dated 01 .02.2024 under section 74 of the CGST Ad,2017 . Counsel for the Petitioner: SRI P.VENKAT PRASAD FOR M/s P.V.PRASAD ASSOCIATES Counsel for the Respondent Nos.1 TO 4: SR! DOMINIC FERNANDES, SENTOR STANDING COUNSEL FOR CBIC Counsel for the Respondent No.5: SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERAL OF INDIA Counsel for the Respondent Nos.6 TO 8: -

The Gourt made the following: ORDER

IN THE HTGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD AND G ... Petitioner No. F DATED: 15.06-2026 Between: M/s. Seven Star Mining Agencies LLP, Sy No.277 to 285, Plot No.328 and333, Lllanguda, Rampally, Rangareddy, Telangana - 50i 301 Represented by its Authorised Signatory Jay Prakash Kumar, S/o. Bir Bahadur Singh AND The Assistant Commissioner of Central Tax, Medchal Division, Medchal Commissionerate, Aditya Towers, Sri Sai Enclave, Old Bowenpally, Secunderabad, Telangana - 500 011 & 7 others Respondents ORDER: Heard Mr. P.Venkat Prasad, leamed counsel representing IWs. P.V. prasad Associates, appearing for the petitioner and Mr. Dominic Fernandes, learned Senior Standing Counsel for Central Board of Indirect Taxes and Customs (CBIC) appearing for respondent Nos.l to 4. 2. The writ petition has been preferred with the following prayer: "For all the reasons stated in the accompanyirrg affidavit, it is prayed that this Hon'ble High Courl may be pleased to issue a writ, order, or direction more particularly one in the nature of writ of mandamus declaring

2 a)TheProvisionsofSectionls(2Xc)oftheCGSTAct'2017aswellas section l6(2xc) of the TGST Act,2017 as arbitrary, without juri iction' unconstitutional; against the principles of natural justice an'd as ultra-vires to the provisions of Article 14, 300A and Article l9(lXg) of the Constitution of lndia. b)Theorder-in-originalNo.|1ot2o23dated0l.02.2024readwithForm DRC-07 bearing zD36O224Ol04l3l dated 07.02.2024 as being void' arbitrary, illegal, without juri iction, without authority of law apart from being violative of Articles la, l9(l)(g) and265 of the constitution of India, and to consequently set aside the same' c)RecoverynoticesinFormGSTDRC13dated10.04.2026issuedto Respondent Nos. 6 to 7 as being void, arbitrary, illegal, without juri iction, without authority of law apart from being violative of Articles l4' l9(l)(g) and265 of the constitution of India, and to consequently set aside the same' d)RecoverynoticesinFormGSTDRC13dated30.09.2025videC.No: VlOllO4/2024 issued to the Respondent no' 8 as being void' arbitrary' iltegal, without juri iction, without authority of law apart from being violative of Articles 14, l9(l)(g) and265 of the constitution of lndia, and to consequently set aside the same and/or pass such further or other order(s) as this Hon,ble court may deem fit and proper in the circumstances of the case."

3.

The petitioner has taken a plea that it came to know of the impugned order when Form GST DRc-13 dated 30.09.2025 was issued to third person - IWs. R.K. Enterprises Earth Moving Spares' The matter relates to tax period from April, 2018 to March , 2}lg. Therefore, the matter is not belated' This Court may entertain the writ petition on the ground that the petitioner was not served with the show cause notice and not aware of the proceedings initiated by the DePartment. :

3

4.

Learned Senior Standing Counsel for CBIC has opposed the prayer at the outset on the ground of huge delay in preferring this writ petition. He has relied upon the decision of the [{on'ble Supreme Coun in Assistant Commissioner (CT) LTU, Kakinada, v. Glaxo Smith Kline Consumer Health Care Limitedr.

5.

Learned counsel for the petitioner, therefore, seeks liberty to the petitioner to prefer an appeal with a delay condonation application in terms of Section 107(1) read with Section 107(4) ofthe Central Goods and Services Tax AcI,2017. He submits that the appellate authority may be directed to consider the question of delay in view of the reasons explained in the delay condonation application

6.

Having regard to the facts and circumstances as noted above, this Court is not inclined to enter into the merits of the issue as the petitioner is being allowed liberty to approach the appellate authority. He may approach the appellate authority within a period of two weeks with a delay condonation application and statutory pre-deposit. It is open for the petitioner to take all such grounds in law and on facrs in the appeal. Needless to say, the appellate authority would consider the question of delay and if it is satisfied with the reasons explained in the delay condonation application, it shall decide the case on ments During the period of two weeks within which the petitioner has to ' lzozo; te scc ot r

4 file an appeal, no coercive steps be taken against the petitioner pursuant to the impugned garnishee notices in Form GST DRC-13 dated 30.09.2025 and t r0.04.2026. 7. The instant Writ Petition is disposed of accordingly. There shall be no order as to costs. Miscellaneous applications, if any pending, shall stand closed. . M.MANJULA JOINT REGISTRAR ,,i'// G SEGTTON OFFICER To 1. The Assistant Commissioner of Central tax, Medchal Division, Medchal commissionerate, Aditya Towers, sri sai Enclave, old Bowenpally' , Secunderabad, Telangana 500 011

2.

The Assistant commissioner of central tax, Karirnnagar Division, 2nd Floor' H.No.8-7-296/l,ManikantaComplex,HanumanNagar,Karimnagar, Telangana 505 001

3.

Additional commissioner of ' central Tax, Hyderabad Audit-ll commissionerate, sanvi Yamuna Pride, 1-9S/B Plot 20 and 21' VIP Hills' MadhaPur, Telangana - 500 081

4.

Joint commissioner of central tax, Medchal commissionerate, 11-4'64918' Lakdikapul, Hyderabad, Telangana 500 004. 5. The Secreiary,-union of lndia] Ministry of Finance, Department of Revenue' North Block, New Delhi 110 001 6'oneCCtorrrusP.V.PRASADASSoClArES,^lvocatetoPUC!-

7.

ONC CC tO SRI DOMINIC FERNANDES' SENIOR STANDING COUNSEL FOR CBIC [oPUC]

8.

ONE CC tO SRI N.BHUJANGA RAO, DEPUTY SOLICITOR GENERAL OF INDIA [OPUC]

9.

Two CD CoPies PSK. TKS "v

HIGH COURT DATED: 1510612026 oI 1Ht sl ORDER WP.No.17 t 92 of 2026 3 07,ttlt 2026 , t- t f spA.Tc.yl DISPOSIN OF THE WRIT PETITION OSTS. G c u 3 li r*\zt

Reproduced from the public record of the Telangana High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.