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

Judgment

I [ 348e I IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) WEDNESDAY, THE TWENTY NINTH DAY OF APRIL TWO THOUSAND AND TWENW SIX PRESENT THE HONOURABLE SRI JUSTICE P.SAM KOSHY AND THE HONOURABLE SRI JUSTICE SUDDALA CHALAPATHI RAO wRlT PETITION NOS: '13688. 13689. 13690.13707,',13712. 13717. 13726. 13727, 13728,13730 ,13733, 13734. 13735. 13736. 13738. 13739.13740. 13742. 13743.

'13745 't3747, 13748. 13753, 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 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 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.2D361125091542G 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. 33,69,650/- for the tax period September 11021 made vide ARN 44360823047 223C on 3 1 -08-2023.

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 2D361125091542G 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: 13689 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.'1 , Survey No 83/1 , Galary 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 (lourt 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 ol the 3rd Respondent bearing Order No.2D36112509'16634 dt.29.11.2025 as beinc, iilegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017, the

J 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, .12,82,371t- for the tax period December 2020 made vide ARN AA361 1220416551 on 30. 1 1.2022, l.A. NO: 2OF 2026 Petition under section 151 CPC praying that in the circumstances stated in the affidavitfiledinsupportofthepetition,theHighCourtmaybepleasedtosuspend the impugned order of the 3rd Respondent bearing order No. 2D3611250916634 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:1359 ooF 2026 Between:

AurobindoPharmaLimited,PlotNo.'l,SurveyNo83/1,GalaryTower'Floor Nii. ZZ_ZI, Hyderabad Knowledge city Raidurg panmaktha, serilingampally ft/|"nO"f, 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-1, Punjagutta Division, Hyderabad' 3'AppellateJointCommissionerofStateTax,PunjaguttaDivision,SthFloor, C.T. ComPlex, NamPallY, HYderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstancesstatedintheaffidavitfiledtherewith,theHighCourtmaybepleased toissueawrit,orderordirection,moreappropriatelyinthenatureofaWritof Certiorari,callingfortherecordsandquashingtheorderofthe3rdRespondent bearing order No. 2D3611250g15765 dt.29'11.2o25 as being illegal, arbitrary, and

4 violative of the provisions of the central Goods and services Tax Act, 2011 , the lntegrated Goods and services Tax Act, 2017 and the Go,cds and services Tax (compensation to states) Acl, 2017 and Articles 14 and 26E-; 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.

AA360523047888Q on 30-05-2023 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. 2D3611250915765 dt.29 11.2025.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRI SWAROOP OOR|LLA, 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, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500b32, Te angana, lnOii Rep by its Authorised Signatory, Mr. T. Deepak ANO ...PET|T|ONER 1. The State OI Telangana, 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, punjaguttir Division, 5th Floor, C.T. Complex, Nampally, Hyderabad ...RESPONDENTS Petition under Articre 226 of the constitution of rndia 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

5 Certiorari, calling for the records and quashing the order of the 3rd Respondent bearing Order No. 2D3611250918181 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 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 O-2024.

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. 2D3611250918181 dt.29.11.2025.

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: 13712OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1 Survey No.83/1 Galaxy Tower Floor Nos. 22-24 Hyderabad Knowledge City Raidurg Panmaktha Serilingampally Mandat 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 the 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 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 Act 2017 and Articles 14 and 265 of the Cons;titution of lndia and consequently direct the Respondents to issue refund of Cess lo the Petitioner of Rs.

1966730/- for the tax period March 2023 made vide ARN. ,\436022505'1 1240 on 28.02.2025.

l.A. NO: 2OF 2026 Petition under Section 1 51 CPC praying that in the circurnstances 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 dl 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, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND '1 . State of Telangana, Revenue (Commercial Tax) De,partment 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

7 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 N( 2D361 '1250918743 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 T 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 4A3608240494485 on 30-08-2024.

LA. 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. 2D3611250918743 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: 13726 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.'1, Survey No.83/1, Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raid urg 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'

8 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.2D361125091750F dt.2911112025 as being ittegal, 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. 2,55,788/- for the tax period January 2('t22 made vide ARN.

AA36 1 223042368C on 30 I 1 212023.

l.A. NO: 2 OF 2026 Petition under Section 151 CPC praying that in the circun.rstances stated in the affidavit filed in suppo( of the petition, the High Court may be pleased to suspend the impugned order of the 3rd Respondent bearing Order Nc. 2D361'1250gi75OF 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

9 w.P.NO:13727 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, Rangi Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER ANO 1. State of Telangana, Revenue (Commercial Tax) Department Rep by its Secretary.

2. Deputy Commissioner (SI), 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 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.7,22,610/- for the tax period July 2023 made vide ARN AA360625051 9430 on 30.06.2025.

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 dt.29.11.2025.

l0 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:

Aurobindo Pharma Limited, Plot No.1, Survey No.B3/1 , Galary Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Te,langana, 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 Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High oourt may be pleased to issue a writ, order or direction, more appropriately in thr: nature of a writ of certiorari, calling for the records and quashing the order ol the 3rd Respondent bearing order No. AD3608240010s89 dt.29.11.202s 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, 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. 1,17,171l- for the tax period september 2o2o made vide ARN.

443608220339 541 on 29.08.2022, l.A. NO: 2 OF 2026 Petition under Section 15i cpc praying that in the circurrstances stated in the affidavit filed in support of the petition, the High court may be pleased to suspend

11 the impugned order of the 3rd Respondent bearing order No. AD3608240010589 dt.29.11.2025 Gounsel for the Petitioner: SRI KAILASH NATH'P.S.S Counsel for the Respondents: SRI SWAROOP OORILLA, SPECIAL GOVT PLEAOER FOR STATE TAX W.P.NO:13730 0F 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 l.stateofTelangana,Revenue(CommerciatTax)DepartmentRepbyits 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 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. 2D3611250915601 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) Act, 2017 and Articles 14 and 265 of the constitution of lndia, and consequently, direct the Respondents to issue refund of cess to the PetitionerofRs.7.1,139/.forthetaxperiodJuly202lmadevideARN AA3606230451 63G on 30-06-2023.

12 l.A. NO: 2OF 2026 Petition under section '151 cPC praying that in the circurnstances 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 l',1o. ZD36.l 12509.15601 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: 13733 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.B3/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Te,langana, tnAii Rep Oy 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 thr-. nature of a writ of certiorari, calling for the records and quashing the order of the 3rd Respondent bearing order No. 2D36112s0918382 dt.29.11.2025 as being iflegal, 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 Articles 14 and 26s of the constitution of lndia, and consequently, 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.

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. 2D3611250918382 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:137340F 2026 Between:

Autobindo Pharma Limited, l survey No.83/1 , Galaxy Tower ,Plot 22-24 ' Hyderabad Knowledge City Panmaktha, Serilingampally Mandal, RingaReddy District, Hyderabad - 500032, 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 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 o.ZD361 '1250919262 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

14 (Compensation to States) Act, 2017 and Articles 14 and 261, 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 Febru€ry 2023 made vide ARN.AA3601 2504941 5L on 31 -01 -2025.

l.A. NO: 2OF 2026 Petition under Section 151 CPC praying that in the circurnstances stated in the affidavit filed in support of the petition, the High Court may t,e pleased to suspend the impugned order of the 3rd Respondent bearing Order No. 2D36112509150SE dt.29.11.2025.

Gounsel 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: 13735 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, Te.langana, lndia Rep by its Authorised Signatory, Mr. T. Deepak ...PETITIONER AND 1. State of Telangana, Revenue (Commercial Tax) De,partment 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 lhe Constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High (lourt may be pleased to issue a writ, order or direction, more appropriately in thr: nature of a Writ of certiorari, calling for the records and quashing the order ol the 3rd Respondent bearing order No. 2D361125091760E dt.2g 11.2025 as being illegat, arbitrary, and

15 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. 5,12,292t- for the tax period May 2021 made vide ARN' AA360 4230 407 838 o n 28 -0 4 -2023 .

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: 13736 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, 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-1, Punjagutta Division, Hyderabad' 3. Appellate Joint commissioner of State Tax, Punjagutta Division, 5th Floor, C.T. Complex, Nampally, Hyderabad.

..,RESPONDENTS Petition under Artide 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 dt_2911112025 as being illegat, 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. 40,50,7111- for the tax period August 2021 made vide ARN.

4A360723039499R on 27 103 12023.

l.A. NO: 2OF 2026 Petition under Section 151 CPC praying that in the circurnstances 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. 2D361i250915928 dt.29t11t2025.

Counsel for the Petitioner: SRI KAILASH NATH.P.S.S Counsel for the Respondents: SRt SWAROOP OORILLA, SPECIAL GOVT PLEADER FOR STATE TAX W.P.NO: 13738 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, Tetangana, 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 Articre 226 ol the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High oourt 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, 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.1,58,129/- for the tax period August 2020 made vide ARN.

AA36072203867 50 on 30.07 .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. 2D361125O91721G 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:13739 0F 2026 Between:

AurobindoPharmaLimited,PlotNo.l,SurveyNo.S3/l,GalaryTower,Floor Nos22-24,HyderabadKnowledgeCityRaidurgPanmaktha,Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, lndia Rep by its Authorised Signatory, Mr. T. Deepak 1 ...PETITIONER AND Revenue (Commercial Tax) Department Rep by its State of Telangana, 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

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 beinq 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 Gocrds 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 4436032304 1 302U on 29-03-2023.

l.A. NO: 2 OF 2026 Petition under section 151 cPc praying that in the circunrstances 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. zD3611zsog1612H 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, Gatary Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Tetangana, lndii Rep by its Authorised Signatory, Mr. T. Deepak AND ...PET|T|ONER 1 2 State of Telangana, Revenue (Commercial Tax) Department, Rep by its Secretary.

Deputy Commissioner (ST), STU-'t, punjagutta Division, Hyderabad.

19 3. Appellate Joint Commissioner of State Tax, Puniagutta 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 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. 2D3611250917381 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, 20'17 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 AA360522041290P on 31 05.2022.

I.A. NO:,2 OF 2026 Petition under Section I 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. 2D3611250917381 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: 13742OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1 Survey No.83/1 Galary Tower Floor Nos. 22-24 Hyderabad Knowledge City Raidurg Pannraktha Serilingampally Mandal Ranga Reddy District Hyderabad - 500032 Tetangana 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 lndizr praying that in the circumstances stated in the affidavit filed therewith, the High lourt may be pleased to issue a writ order or more appropriately in the nature of a \l/rit of certiorari calling for the records and quashing the order of the 3rd Respondent bearing order No.

2D361 N917943 d1.29.11.2025 as being illegat arbitrary and viotative 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. A4360923041388y on 29-09-2023.

l.A. NO: 2 OF 2026 Petrtion under section 151 cpc praying that in the circunrstances stated in the affidavit filed in support of the petition, the High court may b,-. pleased to suspend the impugned order of the 3rd Respondent bearing order N,:. 2D36112s0g17g43 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

21 w.P.No: '13743 OF 2026 Between:

Aurobindo Pharma Limited, Plot No.1, Survey No.83/1 , Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raid urg 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. ZD361125O,2O2OV dt.029.11.2025 as being illegal, arbitrary, and violative of the provisions of the central Goods and services Tax Act, 2017 , the Integrated 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.8,08,300/- for the tax period May 2023 made vide ARN 4A360425050623D on 30.04.2025.

22 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: 13745 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. The State of Telangana, Revenue (Commercial Tax) t)sp2rtrnsnt Rep by its Secretary.

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

3. Appellate Joint Commissioner of State Tax, punjagufla 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 oourt 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. 2D3611250919056 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, 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.16,36,7091 for the tax period June 2O2O made vide ARN.

4A360325052975Y on 31.03.2025.

LA. NO: 2OF 2026 Petition under section 1s1 cpc praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may ber pleased to suspend

23 the impugned order of the 3rd Respondent bearing order No. 2D3611250919056 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: 13747 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 Mandat, 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 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. 2D3611250914231 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 lndia, and consequently, direct the Respondents to issue refund of cess to the petitioner of Rs. 16,17,015t- for the tax period March 2021 made vide ARN AA36022304269 5 A o n 28 -O2 -2023'

21 l.A. NO: 2 OF 2026 Petition under Section 151 CPC praying that in the circurnstances 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 lJo. 2D3611250914231 dt.29.1't.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.B3/1 Galaxy Tower, Floor Nos. 22-24, Hyderabad Knowledge City Raidurg Panmaktha, Serilingampally Mandal, Ranga Reddy District, Hyderabad - 500032, Telangana, India 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, Punjagufla 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 oourt 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.29.11.2025 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

25 Petitioner of Rs. 4,37,0721 - lor the tax period November 2020 made vide ARN AA36 1 0220385230 on 29.09.2022.

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. ZD36'11250916782 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: 13753OF 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 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. Z:D361125O91452H 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

26 (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 2t)21 made vide ARN.

AA36 1 22204 1 450U on 30. 1 2.2022.

l.A. NO: 2OF 2026 Petition under Section 151 CPC praying that in the circurnstances 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, Galary 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) Derpartment Rep by its Secretary.

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

3. Appellate Joint Commissioner of State Tax, Punjaguta 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 (lourt may be pleased to issue a writ, order or direction, more appropriately in thr-. nature of a Writ of Certiorari, calling for the records and quashing the order oj' the 3rd Respondent bearing Order No. 2D3611250919056 dt.29.1 1.2025 as beingr iltegal, arbitrary, and

27 violative of the provisions of the central Goods and services Tax Act, 2Q17 , 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.16,36,7094 for the tax period June 2020 made vide ARN' 44360325052975Y on 3'1.03.2025.

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. 2D3611250919056 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: 13782 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, 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' 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 to issue a writ, order or direction, more appropriately in the nature of a writ of

28 Certiorari, calling for the records and quashing the order c,f the 3rd Respondent bearing Order No. ZD36'1 1250916918 dt.29.11.2025 as being illegal, arbitrary, and violative of the provisions of the Central Goods and Servicr:s Tax Act, 2017, the lntegrated Goods and Services Tax Act, 2017 and the Gor:ds and Services Tax (Compensation to States) Act, 2017 and Articles 14 and 261, of the Constitution of lndia, and consequently, direct the Respondents to issue refund of Cess to the Petitioner of Rs.60,18,938/- for the tax period June 2020 made vide ARN- 4A3606220371 50P on 30.06.2022.

l.A. NO: 2OF 2026 Petition under Section 151 cPC praying that in the circurnstances stated in the affidavit filed in support of the petition, the High Court may b,e pleased to suspend the impugned order of the 3rd Respondent bearing Order No 2D36j125091691B 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.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, Sth Floor, C.T. Complex, Nampally, Hyderabad ...RESPONDENTS

29 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. ZD36'1 1250916292 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) 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.

AA3611230467168 on 30-1 1-2023.

I.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. 2D3611250916292 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 The Court made the following: COMMON ORDER

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD THE HONOURABLE SRI JUSTICE P.S,\M KOSHY AND THE HONOURABLE SRI JUSTICE SUDDALA CHALAPATHI FAO W.P.Nos.13688, r3689, 13690. 13707. 137 12. 137 17,137?6,L3721 , t3728 13730 13733 13734 13735 t3736 137.38 13739 13740 13742 13743 13745 13147 13748 13753 13755 13782 and 13786€fi026 29.04.2026 Between:

Aurobindo Pharma Limited Petitioner AND State of Telangana, Revenue Commercial Tax Department Rep by its Secretary and 2 others Respondents COMMON ORDER (per Hon'ble Sri Justice P.Sctm lioshy) Heard Mr. Kailash Nath P S S, leamed counsel for the petitioner and learned Special Government Pleadel tbr State Taxes for respondents. Perused the record 2.

These are the batch of writ petitions u,hich have been filed challenging the rejection of the claim for relund o1-tax paid againsr on zero rated supply for different periods.

The relevant details in respect of which the petitioner filed individual writ petitions indicating the tax period, the amount of

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

wP 13141/2026 S.No.

Writ petition Tax period Amountof refund (in Rs.)

DateofOrde r ln Original DateofOrde r In Appeal IO wP t368812026 Septembe1202l 33,69,650 09105124 29ll.ll25 1l wP 1368912026 December 2020 12,82,3'11 09t05/24 29fi t/2s t2 w P t3690/2026 June2021 1,65,395 09105124 29111/25 l3 w P t3'7 07 /2026 December 2022 3,s3,40s 07/01125 29111/25 l4 l5 w P t31 12D026 March2023 19,66,730 t6t05125 29111125 wP t3't 17 !2026 Septernbe12022 3 1,09,580 0710112s 291|L125 l6 w ? t 3126/2026 Jantary2022 1 ,96,364 JLrl 2023 7,22,610 09105124 29111125 07108125 29llll2s 11 wPt372112026 t8 wP1372812026 September'2020 | ,t'7 ,l1l 09105124 29il1125 l9 wP137301202.6 July 2021 7 |,t39 09105124 29lll25 20 w P 1313312026 Novembe12022 5,05,290 07 l0 t l2s t6105n5 29lt | 125 2l wPt373412026 February2023 t9,52,318 29111125 22 23 wPt313512026 May202l 5,12,292 09t05124 29lttl25 w? 13136/2026 AugLrst202l w P t3'7 3812026 Au ust2020 40,50,7I I 09105/24 2911 25 t,58,129 09105124 29lt t/25 24 April2021 1,88,409 09105/24 29/11/25 25 wP1373912026 26 wP 13'7 4012026 hne2020 24,93,349 0910s124 29nl125 21 w P t31 4212026 Octobe1202l 4,80,249 09/05124 29,].v2s 28 w P 137 43 12026 May2023 8,08,300 t7t06125 29lt | 125 29 w P t3'7 45/2026 April2023 t6,36,709 t6/0s/25 29lttl25 r6,17,015 09105/24 29/11125 30 March202l

Amouotof refund (io Rs.)

Novembe12020 3 1 WP 137 48/2026 4,37,072 32 wP13153D026 Jantarv2\Zl 41,36,698 33 WP13't5512026 October2022 5 5,44.6 t 4 July 2020 34 \'l?1378212026 60,r8,938 December 2021 3 5 WP t3'1 86/2026 2,55,188 S.No.

Writpetition Tax period '2025 t87 taxmann.com 704 (Telangana) ' zozs 1t1 tll naa Datt ofOrde r|l Ori inal 09/c5t24 29111t25 09105124 01 lc I t25 0915t24 09/)5t24 4.

Recently, the Division Bench of this Fligh Coun headed by the Hon'ble The Chief Justice had taken up an iclentical matter in respect of the very same petitioner i.e., Aur,rbindo Pharma Limited v. State of Telanganar, wherein the Divir;ion Bench has in paragraph Nos.9 to 11 has held as under:

9. The matters have been taken up today. However, at the outset, learned counsel for the respondent State. on instn-rctions, submits that the position in lau,has been clarified by the Division Bench judgment of Gujarat High Oourr in the case of Atul Limited and another v. Union of India and others2. The Gujarat High Court in the case ot' refund of unutilized ITC as against zero-rated supply of compensation cess paid, held that the petitioner in such cases can claim refund of the cess paid on purchase of coa used for manufacturing of goods exported being zero-rated supplies.

The petitioner may have paid the IGST on the gools expo(ed by it, but it was not required to pay an) compensa ion cess as DateofOrde r tn al A 291t1125 29ll I 125 291 | I /25 2911 1125 I I

4 the goods manufactured by the petitioner are exempted from the levy oftax. In such a scenario, the law laid down in the case of Patson Papers Private Limited v. Union of India and others3 would squarely apply to the facts of the present case.

The case of Patson Papers Private Limited (supra) related to the manufacture of dyes and there was purchase of coal in the manufactr,rring 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 Guj arat High Court, the deparlment is inclined to reconsider the matter.

10. Learned coLrnsel fbr the petitioner subrrits lhat 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 tinal 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 refund of accumulated unr-rtiUzed cess but not required to be used for making zero-rated supplies which are non-ta,xable supplies was not proper. Learned counsel for the petitioner further subnrits that the judgment in case of Patson Papers Private Limited (supra) was caried to the Hon'ble Supreme Court by the Revenue and the Special Leave Petition was dismissed.

1 I - We have heard the learned counsel for the parties and taken note of the material facls and the relevant provisions of the Cess Act, CGST Act and IGST Act and the Rules prescribed thereunder. Without further dilating on the position in law as it has been well laid down in the cases ofPatson Papers Private Limited (supra) and Atul Limited (supra), since the department is inctined to reconsider the matter in the light of the decisior.rs referred to hereinabove, the impugned Order-ln- Original and the appellate order are set aside. The matter is remanded to the original authority to take a fresh decision in 'zozs (o) rutt r:q:

5 accordance with law after opportunity of hearillg to the petitioner within a period of four (4) months.

Today, when the matter is taken up lor hearing, the leamed counsel for the petitioner as also the learned ,:ounsel for the respondents do not dispute the fact that the issue inl'olved in these writ petitions is identical which is already disposed of in respect of the very same petitioner in a batch of writ petitions 6.

Given the said fact that the Division Bench of this Court in identical set of facts in respect of the very sam: assessee have allowed the writ petitions and have remanded the rratter back to the original authority to take a fresh decision, in accot dance with law, after giving an opportunity of hearing to the petitioner as has been directed in the other batch of writ petitions. Let the present batch of matters also be decided within a period of four (04) months in accordance with law, after giving an opportunity of hearing to the petltloner.

Accordingly, these writ petitions are allowed with the above direction. No order as to costs

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

SD/-M. OSMAN ALI BAIG ASSISTANT REGISTRAR //TRUE COPY// SECTION OFFICER ./r The Secretary, 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 [OPUC] One CC to SRI SWAROOP OORILLA, SPL GP FOR STATE TAX [OPUC] Two CCs to GP FOR STATE TAX, High Court for the State of Telangana, at Hyderabad. [OUT] Two CD Copies To 7.

PSK.

BS Pr^(.

1 2 J 4 5 b 6

31 HIGH GOURT DATED: 2910412026 E I s lAth COMMON ORDER -v.

WP.NOS: 13688, 13689, 13690, 1 itw;1t712',' 13717, 13726, 13727, 13729, 13730,13733, 13734, 13735, 1 3736, 137 39, 1 3739, 137 40, 137 42, 137 43, 137 45, 13747,13749,13753,13755, 13792 AND 13796 0F 2026 ALLOWING THE WRIT PETITIONS WITHOUT COSTS Mq, rs\u\x