Aurobindo Pharma Limited. v. The State Of Telangana - Telangana High Court, 29 Apr 2026

Judgment

t [ 348s ] IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) WEDNESDAY, THE TWENTY NINTH DAY OF APRIL TWO THOUSAND AND TWENTY SIX PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUST]CE SUDDALA CHALAPATHI RAO WRIT PETITION NOS: 13688. 13689.'13690 .13707.137 12. 13717.',13726 13727 13728. 13730.13733.13734. 13735. 13736 . 13738. 13739.13740. 13742 13743 13745,1 3747. 13748.'.|.3753. 13755. 13782 AND 13786 0F 2026 W.P.NO: 13688 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidu rg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad' 3. Appellate Joint commissioner of state Tax, Punjagutta Division, 5th Floor, C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 ol the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361'125091542G d1.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and Services Tax Act, 2017 , lhe lntegrated Goods and services Tax Act, 2017 and the Goods and Services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of

2 lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs. 33,69,6501 for the tax period September 2021 made vide ARN.

4A360823047 22 3C on 3 1 -08-2023 l.A. NO: 2 OF 2026 Petition under Sectron 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High Court may be pleased to suspend the impugned order of the 3rd Respondent bearing Order No. ZD3611ZSO91S42G dt29.11.2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13689 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak AND ...PET|T|ONER 1 State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary 2. Deputy Commissioner (ST), STU-1 , Punjagutta Division, Hyderabad.

3. Appellate Joint Commissioner of State Tax, punjagutta Division, 5th Floor, C.T. Complex, Nampally, Hyderabad.

...RESPONDENTS Petition under Anide 226 of the constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, mo appropriately in the nature of a writ of certiorari calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D3611250916634 dt.zg.11.2o2s as being iilegar, arbitrary, and 'uiorative of the provisions of the centrar Goods and services Tax Act, 2017, the

J lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of , lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 12,82,3711- lor the tax period December 2020 made vide ARN AA3611220416551 on 30.11 .2022' t.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D361125091663A d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH'P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO:13690 0F 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1, Galary Tower, Floor Nos. 22-2q, Hyderabad Knowled ge City Raid urg- P-anmaktha' Serilingampally M;;d"|, n"ngi n"aoy District, Hyderabad - 500032' Telangana' lndia Rep by its Authorised Signatory, Mr. T Deepak ...PETITIONER AND 1. state of Telangana, Revenue (commercial Tax), Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division' Hyderabad' 3. Appellate Joint Commissioner of State Tax, Punjagutta Division' Sth Floor' C.T. ComPlex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 ol lhe Constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybepleased to issue a writ, order or direction, more appropriately in the nature of a Writ of Certiorari, calling for the records and quashing the order of the 3rd Respondent bearingorderNo.zD3611250915765dt.2g.11.2025asbeingillegal,arbitrary,and

4 violative of the provisions of the central Goods and services Tax Act, 2012, the lntegrated Goods and Servrces Tax Act, 2017 and the Goods and Services Tax (compensation to states) Act, 2017 and Articles i4 and 26s of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs 1,65,395/- for the tax period June 2021 made vide ARN.

,44360523047888Q on 30-05-2023 l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D3611250g1s76s dL29.11 2025.

Counsel for the Petitioner: SRI KAILASH NATH.p.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13707 OF 2026 Between:

Aurobindo Pharma Limited, plot No.1, Survey No.g3/1, Galaxy Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg panmaktha, Seritingampatiy Mandal, Ranga Reddy District, Hyderabad - 500-032, Telangana, lnOiJ nei-Oy its Authorised Signatory, Mr T. Deepak AND .,.PETITIONER ...RESPONDENTS l The state 01 Terangana, state of rerangana, Revenue (commerciar rax) Department Rep by its Secretary.

2. Deputy Commissioner (SD, STU-1, punjagutta Division, Hyderabad.

3. Appellate Joint commissioner of State Tax, punjagutta Division, 5th Froor, C.T Complex, Nampally, Hyderabad Petition under Arlicre 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 appropriatery in the nature of a writ of

5 Certiorari, calling for the records and quashing the order of the 3rd Respondent bearing Order No. 2D3611250918181 dt.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and Services Tax Act, 2017 , the lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 3,53,405! for the tax period December 2022 made vide ARN AA36 1 1 240469842 on 30-1 0-2024.

l.A. NO: 2 OF 2026 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D3611250918181 dt.29.11 .2025.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX w.P.NO: 13712 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1 Survey No.83/1 Galaxy Tower Floor Nos. 22-24 Hyderabad Knowledge City Raidurg Panmaktha Serilingampally Mandal Ranga Reddy District Hyderabad - 500032 Telangana lndia Rep by its Authorised Signatory Mr. T. DeePak ...PETITIONER AND 1. State of Telangana, Revenue Commercial Tax Department Rep by its Secretary.

2. Deputy iommissioner ST, STU-1 Punjagutta Division, Hyderabad' s. Appettate Joint commissioner of state Tax, Punjagutta Division, Sth Floor C.T, Complex NamPallY, HYderabad.

,..RESPONDENTS Petition under Article 226 o1 lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased

6 to issue a writ order or direction more appropriate in the nature of a writ of certiorari calling for the records and quashing the order of the 3rd Respondent bearing Order No. 2D3611250919163 di.29.11.2025 as being illegat arbitrary and violative of the provisions of the Central Goods and Services Tax Act 2017 lhe lntegrated Goods and Servrces Tax Act 2017 and the Goods and Services Tax Compensation to States Act 2017 and Articles 14 and 265 of the Constitution of lndia and consequently drrect the Respondents to issue refund of Cess to the petitioner of Rs.

'1966730/- for the tax period March 2023 made vide ARN. AA3602250511240 on 28 02.2025 l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing Order No. 2D3611250919163 dt.29 11.2025 Counsel for the Petitioner: SRI KAILASH NATH.p.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: '13717 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal Ranga Reddy District, Hyderabad - 500032, Telangana, tnOii Rep by its Authorised Signatory, Mr. T Deepak ...PETITIONER AND 1. State of Telangana, Revenue Secretary.

(Commercial Tax) Department Rep by its 2. Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3. Appellate Joint Commiss]?ng, o.f State Tax, punjagutta Division, 5th Floor, C.T Complex Nampally. Hyderabad ...RESPONDENTS

1 Petition under Priicle 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order N( 2D3611250918743 dt.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017 , the lntegrated Goods and services r Acl, 2017 and the Goods and services Tax (compensation to states) Acl, 2017 and Article 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 31,09,580/- for the tax period september 2022 mad vide ARN AA3608240494485 on 30-08-2024.

.A. NO: 2OF 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D3611250918743 d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH'P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.N :'13726 OF 2026 Between:

Aurobindo Pharma Limited, Plot No 1, Survey No.83/1 , Galaxy Tower, Floor Nos.22-24'HyderabadKnowledgeCityRaidurgPanmaktha,Serilingampally Mandal, Rangi Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department, Rep by its Secretary.

2. Deputy Commissioner (ST), STU-I , Punjagutta Division, Hyderabad'

8 3. Appellate Joint Commissioner of State Tax, Punjagutta Division, 5th Floor, C T Complex Nampally, Hyderabad.

...RESPONOENTS Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more appropnately in the nature of a Writ of Certiorari, calling for the records and, quashing the order of the 3rd Respondent bearing Order No. 2D361 125091750F d1.29111t2025 as being iilegal, arbitrary, and violative of the provisions of the Central Goods and Services Tax Act, 2017, lhe lntegrated Goods and Services Tax Act, 2017 and the Goods and Services Tax (compensation to States) Acl,2017 and Articles 14 and 26s of the constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs. 2,55,7881 for the tax period January 2022 made vide ARN.

AA36 1 22304236 8C o n 30 I 1 2 I 2023 l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No, zD36112sog175oF dt.29t11t2025.

Counsel for the Petitioner: SRI KATLASH NATH.p.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX

9 W.P.NO i 13727 0F 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No 83/1, Galaxy Tower' Floor Nos22-24,HyderabadKnowledgeCityRaidurgPanmaktha,Serilingampally Mandal, nangi neooy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-I , Punjagutta Division, Hyderabad' 3. Appellate Joint commissioner of state Tax, Punjagutta Division, 5th Floor, C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of Certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361125091979R d1.029.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017 ' the lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs.7,22,6101 for the AA360625051 9430 on 30.06.2025.

tax period JulY 2023 made vide ARN:

t.A. NO: 20F 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 suspend the impugned order of the 3rd Respondent bearing Order No 2D361125091979R d1.29.11.2025

10 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Gounsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13728 OF 2026 Between:

LA. NO: 2 OF 2026 Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Tetangana, tnOii Rep by its Authorised Signatory, Mr. T. Deepak AND ...PET|T|ONER 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2 Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3. Appellate Joint commissioner of state Tax, punjagutta Division, 5th Floor, C.T Complex, Nampally, Hyderabad.

...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated rn the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriatery in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. AD360B2400io5B9 dt.29.11.202s as being iilegal, arbitrary. and violative of the provisions of the central Goods and Services Tax Act, 2017, the lntegrated Goods and services Tax Act, 2017 and the Goods and Services Tax (compensation to states) Act 2017 and Articles 14 and 26s of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 1 ,17.171t- for the tax period Septem ber 2020 made vide ARN.

443608220339 541 on 29.08 2022, Petition under Section 'l51 CPC praying that in the circumstances stated in the affidavit fired in support of the petition, the High court may be preased to suspend

11 the impugned order of the 3rd Respondent bearing order No. AD3608240010589 d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH'P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO:13730 0F 2026 Between:

Aurobindo Pharma Limited, Plot No.'1 , Survey No 83/1 , Galaxy Tower' Floor Nis 22-2a, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally VtanOal,RangaReOayDistrict,Hyderabad-500032,Telangana,lndiaRepby its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad' 3.AppellateJointCommissionerofStateTax,PunjaguttaDivision,SthFloor' C.T. Complex, NamPallY, HYderabad ,..RESPONDENTS Petition under Article 226 oI the constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybepleased toissueawrit,orderordirection,moreappropriatelyinthenatureofaWritof Certiorari, calling for the records and quashing the order of the 3rd Respondent bearingOrderNo.ZD3611250915601dl.2g'112025asbeingillegal'arbitrary'and violative of the provisions of the central Goods and Services Tax Act, 2017 ' the lntegrated Goods and Services Tax Act, 2017 and the Goods and Services Tax (Compensationtostates)Acl,2OlTandArticles14and26softheConstitutionof lndia,andconsequently,directtheRespondentstoissuerefundofCesstothe Petitioner of Rs. 71,'1391 for the A4360623045163G on 30-06-2023.

tax period JulY 2021 made vide ARN

t2 l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D361125091s601 dt29 11.2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13733 OF 2026 Between:

Aurobrndo Pharma Limited, plot No.1, Survey No.g3/1, Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal Ranga Reddy District, Hyderabad - 500032, Tetangana, lnOii Rep by its Authorised Signatory, Mr. T Deepak AND ...PET|T|ONER 1. State of Telangana. Revenue (Commercial Tax) Department, Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3. Appellate Joint commissioner of state Tax, punjagutta Division, 5th Floor, C.T Complex, Nampally, Hyderabad.

...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. zD36112so91B3BZ dt.29.11.202s as being iilegal, arbitrary, and violative of provisions of the central Goods and services Tax Act, 2017, the lntegrated Goo and Services Tax Act, 2017 and the Goods and services Tax (compensation to States) Act, 2017 and Articres 14 and 26s of the constitution of rndia' and consequen,y, direct the Respondents to issue refund of cess to the

13 Petitioner of Rs 5,05,290/- for the tax period November 2022 made vide ARN AA361 024043459 on 30-1 0-2024.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPEGIAL GOVT PLEADER FOR STATE TAX W.P,NO: 13734oF 2026 Between:

AutobindoPharmaLimited,lsurveyNo.S3/'l,GalaxyTower'Plot22-24' HyOeraOaa Knowledge City Panmalctha,. Serilingampally Mandal' RangaReOdy District, Hyderab;d - 5OOO32, Telangana, lndia its Authorised Signatory, Mr. T. DeePak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division' Hyderabad' 3. Appellate Joint Commissioner of State Tax, Punjagutta Division' 5th Floor' C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstancesStatedintheaffidavitfiledtherewith,theHighCourtmaybepleased to issue a writ, order or direction, more appropriately in the nature of a Writ of Certiorari,callingfortherecordsandquashingtheorderofthe3rdRespondent bearing order o.zD361 12509 19262 d1.29.11.2025 as being illegal, arbitrary, and violativeoftheprovisionsoftheCentralGoodsandServicesTaxAct,20lT'the lntegrated Goods and Services Tax Act, 2017 and the Goods and Services Tax

l4 (compensation to states) Act, 2017 and Articles 14 and 26s of the constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs 19,52,3181- for the tax period February 2023 made vide ARN.4A360 1 250494 1 5L on 31 -01 -2025 l.A. NO: 2OF 2026 Petition under section 15'1 cPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to suspend the impugned order of the 3rd Respondent bearing Order No. ZD361.1250gi5O5E dt.29.11.2025.

Counsel for the Petitioner: SRt KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13735 OF 2026 Between:

Aurobindo Pharma Limited., Plot No..l , Survey No.g3/.1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowtedge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - b00032, Telangana, lnOii Rep by its Authorrsed Signatory, Mr. T. Deepak ANO ...PETIT|ONER 1 . State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3. Appellate Jornt commissioner of state Tax, punjagutta Division, 5th Froor, C.T. Complex, Nampally, Hyderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit fired therewith, the High court may be pleased to issue a writ, order or direction, more appropriatery in the nature of a writ of certiorari, ca,ing for the records and quashing the order of the 3rd Respondent bearing order No. 2D3611250g1760E dt.29.1 1.2025 as being iregar, arbitrary, and

15 violative of the provisions of the central Goods and Services Tax Act, 2017,lhe lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 5,12,2921- for the tax period May 2021 made vide ARN' AA3604230407 838 on 28-04-2023.

t.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D361125091760E d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH'P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVT PLEADER FOR STATE TAX W.P.No: 13736 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No 83/1, Galary Tower, Floor Nos.22-24,HyderabadKnowledgeCityRaidurgPanmaktha,Serilingampally t,l"nO"l, nangi neody District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department, Rep' by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad' 3.AppellateJointCommissionerofStateTax,PunjaguttaDivision,5thFloor' C.T. Complex, NamPallY, HYderabad.

...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of

t6 Certiorari, calling for the records and quashing the order of the 3rd Respondent bearing Order No.2D3611250915928 d1.29111t2025 as being illegal, arbitrary, and violative of the provisions of the Central Goods and Services Tax Act, 2017, the lntegrated Goods and Services Tax Act, 2017 and the Goods and Services Tax (compensation to States) Aci.2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs 40,50,7111- for the tax period August 2021 made vide ARN.

AA360723039499R on 27 I 03 12023.

l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. zD36112sog1sg2B dt.29t11t2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13738 OF 2026 Between Aurobindo Pharma Limited, Plot No.1, Survey No.g3/1 , Galaxy Tower, Floor Nos 22-24, Hyderabad Knowtedge City Raidurg panmaktha, Serilingampalty Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, tndii Rep by its Authorised Signatory, Mr. T Deepak AND ...PET|T|ONER '1 . State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

! Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3 Appellate Joint commissioner of state Tax, punjagutta bivision, 5th Froor, C.T. Complex, Nampally, Hyderabad ,,.RESPONDENTS Petition under Arlicte 226 of the Constitution of lndia praying that in the crrcumstances stated in the affidavit fired therewith, the High court may be pleased

17 to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361125091721G d1.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 20'.17 , the lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the petitioner of Rs.1,58,129/- for the tax period August 2020 made vide ARN.

4A36072203867 50 on 30.07 .2022 .A. NO: 2OF 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D361125O91721G dt.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH.P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: '13739 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No 83/1, Galaxy Tower' Floor Nis 22_24, Hyderabad Knowledge city Raidurg panmaKha, Serilingampally Mandal, Ranga RedOy District, Hyderabad - 5OOO32, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad 3.AppellateJointCommissionerofStateTax,PunjaguttaDivision,SthFloor, C.T. ComPlex, NamPallY, HYderabad ...RESPONDENTS

18 Petition under Article 226 of the Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a Writ of certiorari. calling for the records and quashing the order of the 3rd Respondent bearing Order No 2D361125091612H dt.29.11.2025 as being iilegat, arbitrary, and violative of the provisions of the Central Goods and Services Tax Act, 2017, the lntegrated Goods and services Tax Act, 2o1z and the Goods and Services Tax (compensation to States) Act, 2017 and Articles 14 and 26s of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs '1 ,88,4091 for the tax period April 2021 made vide ARN AA36032 304 1 3 02U on 29 -03-2023.

l.A. NO: 2 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D36112s0g1612H dt 29 .11 .2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13740 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.g3/1 , Galary Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal Ranga Reddy District, Hyderabad - 500032, Tetangana, f nOii nep Uy its Authorised Signatory, Mr. T. Deepak AND ...PET|T|ONER '1. State of Telangana, Secretary.

Revenue (Commercial Tax) Department, Rep by its 2. Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad

19 3. Appellate Joint Commissioner of State Tax, Punjagutta Division, Sth Floor, C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased toto issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361125O917381 d1.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017, lhe lntegrated Goods and services Tax Act, 2O17 and the Goods and services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs.24,93,3491 for the tax period June 2020 made vide ARN AA36O522041290P on 3 1 .05.2022.

l.A. NO: 2 OF 26 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 suspend theimpugnedorderofthe3rdRespondentbearingorderNo.zDs6ll2so9lT3Sl d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH'P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX

20 W.P.NO: 13742 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1 Survey No_83/1 Galaxy Tower Floor Nos. 22-24 Hyderabad Knowledge City Raidurg Panmaktha Serilingampally Mandal Ranga Reddy District Hyderabad - 500032 Telangana lndia, Rep. by its Authorised Signatory Mr. T. Deepak ...PETITIONER AND 1 . State of Telangana, Revenue Commercial Tax Department Rep by its Secretary.

2. Deputy Commissioner ST, STU-1 Punjagutta Division Hyderabad.

3. Appellate Joint Commissioner of State Tax, punjagutta Division Sth Floor C.T.

Complex Nampally Hyderabad.

2D361 N917943 dr29.11 2025 as being illegat arbitrary and violative of the provisions o the central Goods and services Tax Act 2017 lhe lntegrated Goods and services Tax Act 2017 and the Goods and services Tax compensation to states Act 2017 and Articles '14 and 265 of the constitution of lndia and consequenfly direct the Respondents to issue refund of cess to the petitioner of Rs.4g0249/- for the tax period October 2021 made vide ARN. 44360923041 388y on 29_09_2023 l.A. NO: 2 OF 2026 Petition under Section l51 cpc praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to suspend the impugned order of the 3rd Respondent bearing order No. zD3611ziog17g43 dl29.11 2025 Counsel for the petitioner: SRI KAILASH NATH.p.S.S Counset for the Responde-nts: SRI SWAROOP OOnlf_f_e, SPECIAL GOVT PLEADER FOi STATE TAX

2l W.P.NO:137 43oF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos.22-24,HyderabadKnowledgeCityRaidurgPanmaktha,Serilingampally Mandal, Rangi neddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1 . State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad 3. Appellate Joint Commissioner of State Tax, Punjagutta Division, sth Floor, C.T. ComPlex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of Certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No.2D361125092020V dt.029.11.2025 as being illegal, arbikary, and violative of the provisions of the central Goods and Services Tax Act, 2017 ' lhe lntegrated Goods and services Tax Act, 2017 and the Goods and Services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the PetitionerofRs.8,08,300/-forthetaxperiodMay2023madevideARN AA360425050623D on 30.04'2025.

l.A. NO: 2 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 suspend theimpugnedorderofthe3rdRespondentbearingorderNo.zD36ll2s09202ov dt.29.11.2025.

22 Counsel for the Petitioner: SRI KATLASH NATH.p.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13745 OF 2026 Between:

l.A. NO;2 oF 2026 Aurobindo Pharma Limited., Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lnOii Rep by its Authorised Signatory, Mr. T. Deepak AND ...PET|T|ONER 'l . The State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (SD, STU-1 , punjagutta Division, Hyderabad.

3. Appellate Joint commissioner of state Tax, punjagutta Division, 5th Floor, C.T. Complex, Nampally, Hyderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No.2D36112509i9056 dt.29.11.202s as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017, the lntegrated Goods and services Tax Act, 2o1z and the Goods and Services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequenfly, direct the Respondents to issue refund of cess to the Petitioner of Rs 16.36,709r for the tax period June 2020 made vide ARN.

AA360325052975Y on 31 .03 2025.

Petition under Section 1 51 cpc praying that in the crrcumstances stated in the affidavit fired in support of the petition, the High court may be pleased to suspend

23 the impugned order of the 3rd Respondent bearing order No. 2D361 1250919056 dt.29.11.2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO:13747 0F 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1, Galaxy Tower, Floor Nos 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak .,.PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division' Hyderabad' 3. Appellate Joint commissioner of State Tax, Punjagutta Division, Sth Floor, C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361125O914231 d1.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017 , the lntegrated Goods and services Tax Act, 2017 and the Goods and Services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the petitioner of Rs. 16,17,015L for the tax period March 2021 made vide ARN AA36022304269 5A on 28-02-2023

24 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 suspend the impugned order of the 3rd Respondent bearing Order No. 2D3611250914231 dt29 11 2025.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13748 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampalty Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-i, Punjagutta Division Hyderabad.

3. Appellate Joint Commissioner of State Tax, punjagutta Division, 5th Floor, C.T. Complex Nampally, Hyderabad.

...RESPONDENTS Petitron under Arlicle 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D3611250916782 dt.29.11.202s as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, zo1l , the lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to States) Act, 2oi7 and Articres 14 and z6s of the constitution of India' and consequenry, direct the Respondents to issue refund of cess to the l.A. NO: 2OF 2026

25 Petitioner of Rs. 4,37,0721 - for the tax period November 2020 made vide ARN AA361 0220385230 on 29.O9.2022.

t.A. NO:2OF 2026 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D3611250916782 dt.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVT PLEADER FOR STATE TAX w.P.

O: 13753 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1 , Punjagutta Division, Hyderabad' 3. Appellate Joint commissioner of state Tax, Punjagutta Division, 5th Floor, C.T. Complex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361125091452H d1.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017, the lntegrated Goods and services Tax Act, 2017 and the Goods and Services Tax

20 (Compensation to States) Act, 2017 and Articles 14 and 265 of the Constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs 47.36.6981 for the tax period January 2021 made vide ARN.

44361222041450U on 30 12 2022.

l.A. NO: 2OF 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 suspend the impugned order of the 3rd Respondent bearing Order No. 2D361125091452H dt.29 11.2025 Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13755 OF 2026 Between:

Aurobindo Pharma Limited., Plot No.'1 , Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secreta ry.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad.

3. Appellate Joint Commissioner of State Tax, punjagutta Division, Sth Floor, C.T. Complex, Nampally, Hyderabad.

...RESPONDENTS Petition under Arlicle 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriatery in the nature of a writ of certiorari, ca'ing for the records and quashing the order of the 3rd Respondent bearing Order No. ZD3611250919056 dt.2g.11.2025 as being illegal, arbitrary, and

27 violative of the provisions of the central Goods and services Tax Act, 2017,lhe lntegrated Goods and services Tax Act, 2017 and the Goods and services Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia,andconsequently,directtheRespondentstoissuerefundofcesstothe PetitionerofRs.l6,36,T0gLforthetaxperiodJune2020madevideARN' AA36032505297 5Y on 31 .03.2025.

t.A. NO:2OF 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 suspend the impugned order of the 3rd Respondent bearing order No. 2D361 1250919056 d1.29.11 .2025 Counsel for the Petitioner: SRI KAILASH NATH'P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO:137820F 2 26 Between:

Aurobindo Pharma Limited,, Plot No.1, Survey No 83/1 , Galary Tower' Floor 'Nii_-iz-_z+, Hyderabad Knowledge city Raidurg p-anmaktha, Serilingampally Mandat, Rangi Reody District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1 . State of Telangana,, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad' 3. Appellate Joint Commissioner of State Tax,, Punjagutta Division' 5th Floor' C.T. ComPlex, NamPallY, HYderabad' ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstancesStatedintheaffidavitfiledtherewith,theHighcourtmaybepleased toissueawrit,orderordirection,moreappropriatelyinthenatureofaWritof

28 certiorari, calling for the records and quashing the order of the 3rd Respondent bearing Order No 2D3611250916918 dt.29.11.2025 as being illegat, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017, the lntegrated Goods and Services Tax Act, 2017 and the Goods and services Tax (compensation to states) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs.60,18,9381 for the tax period June 2020 made vide ARN- AA360622037150P on 30 062022 l.A. NO: 2 OF 2026 Petition under Section '151 cpc praying that in the circumstances stated in the affidavrt filed in support of the petition, the High court may be pleased to suspend the impugned order of the 3rd Respondent bearing order No. 2D361i250916918 dt.29 11.2025 Counsel for the Petitioner: SRI KAILASH NATH.p.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13786 oF 2026 Between:

Aurobindo Pharma Limited., plot No..1 , Survey No.g3/1 , Galaxy Tower, Floor Nos 22-24, Hyderabad-Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District. Hyderabad - SO0-032, Telangana, f nAiS nep OV its Authorised Signatory, Mr. T. Deepak AND ...PET|TIONER 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (ST), STU-1, punjagutta Division, Hyderabad.

3. Appellate Joint Commrssigngr of State Tax, punjagutta Division, 5th Floor, C.T. Complex. Nampally. Hyderabad .,.RESPONDENTS

29 Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or direction, more appropriately in the nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D361't250916292 dt.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017 , lhe lntegrated Goods and services Tax Act, 2017 and the Goods and serviceS Tax (compensation to states) Acl, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the Petitioner of Rs. 2,55,788/- for the tax period December 2021 made vide ARN.

AA361 1230467168 on 30-1 1-2023 t.A. NO:2OF 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 suspend the impugned order of the 3rd Respondent bearlng order No. 2D3611250916292 d1.29.11.2025.

Counsel for the Petitioner: SRI KAILASH NATH.P'S'S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX The Court made the following: COMMON ORDER

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAT) THE IIONOLRABLE SRI JUSTICE P.SAM KOSHY AND I'HE HONOURABLE SRI JT'STICE SUDDALA CHALAPATHI RAO W.P.Nos.13688, 13689, 13690, 13707 , 137 12, t37 17, 131 26, 13727, 13728 13730 13733 13734 13735 13736 13738 13739 13740 13742 13743 13745 137 47 13748 13753 13755 13782 and 13786'€T-2026 29.04.2026 Between Aurobindo Pharma L.imited AND Srate o1' Ielanp.ana.

Revenue Comrnercial Tax Department llep by its Secretarl and 2 others COMMON ORDER. (per Hon ble Sri Justicc P Sam Koshtt Petitioner , Respondents petitioncr ancl learnecl Special Government Pleader for State Taxes lor respondents. Pcruscd the record IIcard \4r. Kailash Nath P S S. leamed counsel for the :.

These are the batch of writ peririons u,hich have been filed challenging the rejecrion of the claim for refund oI tax paid against on z!'ro ratcd suppll Ibr difterent periods 3.

'Ihc rclc'ant cletails in respcct of *,hich the petiti.ner filed individual u rit petrtions indicating the tax period, the amount of

refund claim, the date of Order-In-Original and the date of Order-In- Appeal are furnished in the form of tabulation chart hereinunder:

72 wPt3136/2026 24 wPt313812026 w P t3'73912026 April 2021 29 w P I 31 4'7 /2026 DateofOrde rin Original I APPeal DateofOrde r rn Amountof refund (in Rs.)

Tax period Writ petition S.No.

29fi1/25 09l0sn4 33,69,650 Sep tenrber202l wP 13688/2026 l0 29/rU25 0910s124 12,82,31 t December 2020 w P 1368912026 29t1U25 0910s124 r65 195 12 2911t/25 07/0t 125 3,53,405 l3 June202l wP t369012026 Decenber 2022 w P 137 01 12076 29/11125 t6105125 t9,66,730 M arch2023 wP1311212.026 0710t/25 l4 l5 09/05/24 29/t U25 29/t t 125 29t1v25 07108125 t6 t1 29111125 09105/24 31,09,580 wP t37 1712026 7 ,96,364 w?13126/2026 I Jul 2023 Septernber2022 Janttar y2022 September2020 7 ,22,6t0 I,17 ,t'7 I w P 13',121 12026 wP1372812026 l8 29/I1125 09105124 't 1,139 July 7021 wPt3730t2026 Novernbe12022 l9 20 29/t I125 29lll25 0'7101/2s 5,05,290 1610512s 19,s2,3I 8 F ebruary2023 w P t3133 12026 w?1373412026 2l 29lttl25 09105,24 wPt3135/2026 29/lL125 09t05124 29il125 09105/24 5,12,292 May202l 40,50,71 I August202l I ,58,129 Au ust2020 29/|1125 09/0s124 t,88,409 25 29lnl25 0910s124 24,93,349 Jme2020 w P t31 4012026 26 29t1t/25 09/05124 4,80,249 Octobe1202l 29/t 25 t'|106/25 8,08,300 lAay2023 w P t37 4212026 wP t314312026 27 28 29t1v25 t6105125 t6,36,709 April2023 w P t3'7 45 /2026 30 March202l r6, r7,015 09105124 29^112

S.No. \Vritpetition Tax period AmouIltof refund (in Rs.)

DateofOrde r in DateofOrde r in r - 1-- Ori inal eal \ovembe12020 4,37,072 49t05/24 29 | I 1/25 t-"",yZOZr I-,1?J6FS8 09t05124 2911t /25 - 3l -\!u7!!q026 i 32 WPt r 75l /2026 l3 W P I .r r-5 5i2026 October2022 l4 wl)li?82'2026 July 2020 01,t0t /25 60, t8.918 09/05121 2,5 5,7 8 8 09,,0st24 55,14,61.1 29it I t25 29/1 I t25 l5 WI'I .r 786,'2026 Decerrber 2021 29^ I t25 -1. Recentll , the [)ivision Bench of this High Courr headed by Ll're I lon'ble 'fhe Clhief Justice had taken up an identical matter in lespect of the verv same petitioner i.e,, Aurobindo pharma Limited v. State of 'Ielanganar, wherein the Division Bench has in paragraph Nos.9 to I I has held as under 9. l'hc rnatlers har.e been taken up todav. Hora.ever. at rhe outset. Iearne,:l counsel lor the r.espondent Slate. on instrucrions. sLrhmits that the position ir lair has been clarified br tle Dir ision Bench .ludgment of' Gu. arar High Court in the casc of Atul Limited and another r. Union of India and othersr. -l'he (iujarat Iligh Court in rhe case of refund of unutilized ITC as against zero-rated suppiy of compensation cess paid. held that the petitioner in such cases can claim retirnd of the cess paid on purchase of coal used for manulircturinq ol goods exported being zero-rated supplies.

Thc petitioner ma1 have paid the IGST on rhe goods exported b1 it. b,ut ir uas not required to pa\ an) ci\mpensation cess as '.'OZS t8t taxrnann corn 70,1 (Telangana) - 202s (7) TMt 17 )8 i

4 the goods manufactured by the petitioner are exempted from the levy oftax. ln such a scenario, the law Iaid down in the case of Patson Papers Private Limited v' Union of India and otherss would squarely apply to the facts of the present case.

The case of Patson Papers Private Limited (supra) related to the manufactule of dyes and there was purchase of coal in the manufacturing process. It was involved in production of finished goods which was not liable to GST. Finished goods were exported being zero-rated supply. It is submitted that in the light of the ratio rendered by the Gujarat High Court, the deparhent is inclined to reconsider the matter.

10. Learned counsel lbr the petitioner submits that in the present case, position in law would remain the same as lhe coal is used as an input for manufacturing purposes undertaken by the petitioner the final product of which is exported. These exports are to the SEZ and are exempted from levy of tax. If that be the case, the stand of the respondent department to reject the relund of accumulated unutilized cess but not requiled to be used for making zero-rated supplies which are non-taxable supplies was not proper. Leamed couttsel for the petitioner furthet subnrits that the judgment in case of Patson Papers Private Limited (supra) was canied to the Hon'ble Supreme Court by the Revenue and the Special Leave Petition was dismissed.

I l. We have heard the learned counsel fbr the parties and taket.t note of the material facts and the relevant provisions of the Cess Act, CGST Act and IGST Act and the Rules prescribed thereunder. Without furthel dilating on the position in law as it has been well laid down in the cases of Patson Papers Private Limited (supra) and Atul Limited (supra), since the departrnent is inclined to reconsider the matter in the light of the decisions referred to hereinabove, the impugned Order-In- Originat and the appetlate order are set aside The matter is remanded to the original authority to take a fresh decision in 'zozs 161 tvt t:a:

5 accordance with la$ after opportunit) of hearing to the petitioner within a period of four (4) months.

Today. rvhen the matter is taken up lor hearing, the leamed counsel fbr the petitioner as also the lcamed counsel for the respondents do not dispute the fact that the issue involved in these w'rit petitions is identical w,hich is already disposed of in respect of the very sanre petitioucr in a batch of writ petitions.

Gir en the said tact that the DivisLon Bench of this Court in identical seL of f'acts in respect of the vcrv same assessee have allorved the rvrit petitions and have remanded the matter back to the original authoritl to take a fresh decision, in accordance rvith law, after gir ing en opportunity of hearing to thc petitioner as has been directed in the other batch of writ petitions. Let the present batch of nratters also be decidcd within a period of four (04) months in accordance riith lau. alter giving an opporrunity of hearing to the petitroner 1.

Accordinglr,, thcse writ petitions are allowecl with the above direction. \o order as to costs

6 To Miscellaneous applications pending, if any, shall stand closed.

SD/.M. OSMAN ALI BAIG ASSISTANT REGISTRAR //TRUE COPY// SECTION OFFICER 14 Se"r"t"ry, State of Telangana, Revenue (Commercial Tax) Department Deputy Commissioner (ST), STU-1, Punjagutta Division, Hyderabad.

Appellate Joint Commissioner of State Tax, Punjagutta Division, 5th Floor, C.T. Complex, Nampally, HYderabad One CC to SRI KAILASH NATH.P.S.S, Advocate IOPUCI One CC to SRI SWAROOP OORILLA, SPL. GP FOR STATE TAX [oPUCI Two CCs to GP FOR STATE TAX, High Court for the State of Telangana, at Hyderabad. [OUTI Two CD Copies 1 2 3 4 5 o 7.

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3l HIGH COURT DATED: 29t0412026 COMMON ORDER /:,- ( .== 0Il t Hts 16 itttt lti / tto o * WP.NOS: 13688 13689 13690 13707 +3712 13717 13726, 13727 , 13729, 13730, 13733, 13734,13735, 13736, 13739, 13739, 13740, 13742, 13743, 13745, 137 47, 137 49, 137 53, 137 55, 13782 AND 1 3796 0F 2026 ALLOWING THE WRIT PETITTONS WITHOUT COSTS G)?'q' rs\u\x