Saini Semiconductors PVT. LTD. vs. The Assistant Commissioner Of Central Tax

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WP/18067/2026HC TelanganaGSTCNR HBHC01037317202615 June 2026Bench: APARESH KUMAR SINGH,G.M. MOHIUDDIN7 pages
For Respondent: SRI DOMlNlc FERNANDES' SENIOR, STANDING COUNSEL FOR CENTRAL BOARD OF INDIRECT TAXES AND, cusToMS (CBIC), Counset for the ResPondent No'4, SOLICITOR GENERAL OF INDIA, SRI N.BHUJANGA RAO, DEPUTY

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Cause title — parties, addresses and appearances
[ 34881 IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Originat Jurisdiction) MONDAY, THE FIFTEENTH DAY OF JUNE TWO THOUSAND AND TWENTY SIi PRESENT THE HONOURABLE THE CHIEF JUSTICE SRI AND APARESH KUMAR SINGH THE HONOURABLE SRIJUSTICE G.M. MOHIUDDIN F Saini Semiconductors p!rt. Ltd., Shed No. 53, plot No. 166/E, IDA phase ll, cherlapattv, Hvderabad. rehngana-!06:G;' R;;r"."rtecr by its Managins Director, Shri. Mahesh Saini, 56. r_ate nnanJ rumlJiEarni, Aged 50 years, R/o. Villa No. 70, Sitver Oak Viila, Ctrerraparfy, [V;;;; ietangana 500 051. 1' The Assistant commissioner of centrar rax, Uppar .GST Division, Secunderabad GST Commissionerate, s_a_t dii., eii.nt E;fi* ;;il;il: 2nd Floor, Ramanthapur, Hyderabad SfjO-Ofe. - - 2 The Assistant commissioner of centrar rax, Anti Evasion, secunderabad GST Commissionerate, GST Bhawan, e;.d;b"g'h, Hyderabad SOO OO4. 3' The Assistant commissioner of centrar ra-x, Kapra GST Division, Secunderabad GST commissionerate,-s_+_ireZ er"sini EJin* eribir;, 2nd Floor, Ramanthapur, Hyderabad SfjObfS. - -' 4' Union of rndia' Ministrv of Finance, Represented by its secretary, North Brock, New Dethi-110 00i Petition Under Articre 226 0f the constitution of rndia praying that in the circumstances stated in the affidavit fired therewith, the High court may be preased to issue a writ, order, or direction more particurarry one in the nature of a writ of Mandamus declaring that i. lmpugned order-in-originat bearing order No. g4l2o24_ 25-Ajn(AC)-GST dated 17-0g.2024 arong with consequentiar forms in Form DRc 07 vide Reference Nos. ZD361O24O11S3OS, 2D361024011544W and TS 2D361024011549M, 7]D361024011559L dated 10',102024', passed by the Respondent No. 1 under the provisions of section 74 of the CGST/TSGST Acl'2017 as being void, arbitrary. illegal, without jurisdiction, without authority of law apart from being violative of Articles 14, 19(1)(g) and 265 of the constitution of lndia' and directingRespondentNo.ltotreatand/orre-adjudicatethedemandcontained therein .as one falling under section 73 of the GGST/TSGST Act' 2017' so as to make the Petitioner eligible for the benefit of the Amnesty Scheme under Section 128Aof the CGST/TSGST Act, 2017 and to consequently set aside the same' |.A.NO:1 OF 2026 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 operationofimpugnedorderinorder-in-originalbearingorderNo.g412024-25- Ajn(AC)-GST dated 17.0g.2024 along with consequential forms in Form DRC 07 vide Reference Nos ZD3 610240115305, 2D361024011544W and 2D361024011549M' 2D361024011559L dated 10.10 2024 issued by the Respondent No'1' COUNSEI fOr thE PEtitiONET : SRI V.SAI AMIT' COUNSEL REPRESENTING M/s P.V.PRASAD ASSOCIATES counsel for the Respondent Nos.1 to 3 : SRI DOMlNlc FERNANDES' SENIOR STANDING COUNSEL FOR CENTRAL BOARD OF INDIRECT TAXES AND cusToMS (CBIC) Counset for the ResPondent No'4 SOLICITOR GENERAL OF INDIA SRI N.BHUJANGA RAO, DEPUTY

The Court made the following ORDER

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD AND DATED: 15.06.2026 Between: M/s. Saini Semiconductors Pvt. Ltd., Shed No.53, Plot No.166lB,IDA Phase II, Cherlapally, Hyderabad, Telangana - 500 051 Represented by its Managing Director, Shri Mahesh Saini, S/o. Late Anand Kumar Saini ... Petitioner AND The Assistant Commissioner of Central Tax, Uppal CGST Division, Secunderabad GST Commissionerate, l-i-tlSlz,Elegant Edifice Building, 2nd Floor, Ramanthapur, Hyderabad - 500 013 & 3 others Respondents ORDER: Heard Mr. V.Sai Amit, learned counsel representing iWs. P.V. Prasad Associates, for the petitioner, Mr. Dominic Fernandes, learned Senior Standing Counsel for Central Board of Indirect Taxes and Customs (CBIC) appearing for respondent Nos.l to 3 and Mr. K.Mahesh, learned counsel representing Mr' N'Bhujanga Rao, learned Deputy Solicitor General of India, appearing for respondent No.

4.

TI PE \\

2 2 The rvrit petition has been preferred with the following prayer: "For all the reasons stated in the accompanying aflidavit, it is prayed that this Hon'ble High Court may be pleased to issue a writ, order, or direction rnore particularly one in the nature of a Writ of Mandarnus declaring that i. Impugned Order-in-Original bearing Order No 94l2024-25-Ajn(AC)- GST dated 17 .09.2024 along with consequential lbrms in Form DRC 07 vide Reference Nos. 2D36102401 15305, 2D361024011544W and ZD3 6 l 0240 l 1 5 4gM, ZD3 6 l O24O l 1 5 59L dated 1 0.1 0.2024, passed by the Respondent No. I under the provisions of Section 74 of the CCST/TSGST Act, 2017 as being void, arbitrary, illegal, without juri iction, without authority of law apart from being violative of Articles 14, I 9( I )(g) and 265 of the Constitution of lndia, and directing Respondent No. I to treat and/or re-adjudicate the demand contained therein as one falling under Section 73 ofthe CGST/TSGST Act' 2017 ' so as to make the Petitioner eligible for the bcnefit of the Amnesty Schente under Section l28A of the CGST/TSGST Act, 2017 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. ii. Impugned order in Form SPL-07 vide Order Ref' No ZD361 12504101 3 I andZD36|l2504l059Ldatedl3-ll.2025passedbytheRespondentNo.3 under the provisions of CGST/TSGST Act' 201'7 as being void' arbitrary' illegal, without juri iction, without authority of larv apart from being violative of Articles 14, l9(lXg) and 265 ofthe 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 deern fit and proper in the circumstances of the case

3.

Learned counsel for the petitioner seeks to confine his prayer to challenge to the order-in-original dated 17'09'2024 andhe submits that petitioner would not be pressing the challenge to the rejection of his application for availing AmnestY Scheme'

J

4.

Learned Senior Standing Counsel for CBIC submits that the Amnesty Scheme is applicable only in cases covering the proceedings under Section 73 of the Central Goods and Services Tax Act,2017 (hereinafter referred to as 'the Act').

5.

However, after some arguments, learned counsel for the petitioner seeks liberty to the petitioner to prefer an appeal against the impugned order-in- original. He submits that some delay might have been occurred in approaching n n the appellate authority and therefore, it may be directed to consider the delay.

6.

Learned Senior Standing Counsel for CBIC submits that the petitioner was at liberty to prefer an appeal against the impugned order-in-original taking all the grounds as are available in law and on facts before the appellate authority in respect of the subject tax period.

7.

However, upon hearing the learned counsel for the parties, since the petitioner seeks liberty to prefer an appeal, we do not wish to comment on the merits of the contentions raised by the parties.

8.

We grant liberty to the petitioner to prefer an appeal within a period of two weeks with statutory pre-deposit and a delay condonation application. The petitioner may take all such grounds of law and facts in the memo of appeal as are available to it. Needless to say, the appellate authority would consider the I \

4 question of delay taking into account the aforesaid facts and circumstances and ifit is satisfied on the point ofdelay, proceed to decide the appeal on merits in accordance with law.

9.

The Writ Petition is accordingly disposed of with the aforesaid liberty. There shall be no order as to costs. Miscellaneous applications pending, if any, shall stand closed. A.H.S. GOWRI SHANKAR EFFII T REGISTRAR //I/ TION OFFICER I t -\_ lo

1.

The Assistant Commissioner of Central Tax, Uppal CGST Division, secunderabad GST Commissionerate, 3-4-11812, Elegant Edifice Building, 2nd Floor, Ramanthapur, Hyderabad 500 013. 2. The Assistant commissioner of central Tax, Anti Evasion, secunderabad GST Commissionerate, GST Bhawan, Basheerbagh, Hyderabad 500 004' 3.TheAssistantCommissionerofCentralTax,KapraGSTDivision' secunderabad GST Commissionerate, 3-4-11812, Elegant Edifice Building, 2nd Floor, Ramanthapur, Hyderabad 500 013' 4. ihe Secretary, Union of lndia, Ministry of Finance North Block' New Delhi- 110 001. s. onl Cc to Mis P.V.PRASAD ASSoCIATES, Advocate [oPUc]

6.

ONC CC tO SRI OOITAIT'TIC-TTNT'TANDES, SE[!I-OR STANDING COUNSEL FOR CENTRAL BOAFiDbi_ir'rOriEC[ TAXES AND CUSTOMS (CBIC)' Advocate (OPUC) 7. one CC to SRI N.BHUJANGA RAo, Deputy Solicitor General of lndia Advocate [OPUC] L Two CD CoPies SA BS

HIGH COURT DATED: 1510612026 ORDER WP.No.18067 of 2026 DISPOSING OF THE W.P WITHOUT COSTS. p( oo 0 2 JUt 2mE ! ttrE STAIA- ( ,( q' i i -.,,,_,9 , r\n\tu' ii

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.