A Chandraiah vs. Additional Commissioner And Appellate Authority

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WP/14491/2025HC Andhra PradeshGSTCNR APHC01028567202524 June 2025Bench: R RAGHUNANDAN RAO,SUMATHI JAGADAM7 pages
For Petitioner: M V J K KUMARFor Respondent: GP FOR COMMERCIAL TAX

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Cause title — parties, addresses and appearances
r *v. H, APHC010285672025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE TWENTY FIFTH DAY OF JUNE TWO THOUSAND AND TWENTY FIVE PRESENT THE HON’BLE SRI JUSTICE R RAGHUNANDAN RAO AND THE HON’BLE SMT JUSTICE SUMATHI JAGADAM WRIT PETITION NO: 14491 OF 2025 Between: A Chandraiah, Works Contractor S/o. Late. A. Appaiah. Aged about 55 years 91/3, Errabalem Road, Kollamitta, Sullurpet - 524 121, Tirupati District. ...Petitioner AND Additional Commissioner (ST) and Appellate Authority, Tirupati, Tirupati District, Andhra Pradesh. The Deputy Assistant Commissioner (ST)-1, O/o. Commissioner (ST), Gudur Circle, Andhra Pradesh. The Assistant Commissioner (ST), Gudur Circle, Gudur, SPSR Nellore District Andhra Pradesh. Union of India, Represented by its Secretary, Ministry of Finance, New Delhi -110001. State of Andhra Pradesh, Rep by its Principal Secretary, Revenue (CT) Department, Velagapudi, Amaravathi, Guntur District, Andhra Pradesh. 1. 2. Assistant Gudur, SPSR Nellore District, 3. 4. 5. ...Respondents % 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 an appropriate writ, order or direction particularly in the nature of Writ of MANDAMUS declaring the action of the 3rd Respondent in issuing the endorsement dated 24-04-2025 in A.O. No. DIN3723042521818 in Spl. Apl. No. 322, 323, 324 and 325 /2024- 25/CTR rejecting the appeal filed by the Petitioner on the ground of limitation also the orders passed by the 1st Respondent -Deputy Assistant Commissioner (ST)-1, Gudur Circle dated 10-10-2023 for 2017-18, 09-10-2023 for 2020-21, 10-10-2023 for 2021-22 and 10-10-2023 for 2022-23 under Section 73 of GST Act 2017 in not following the principles of natural justice, and the order do not bear the DIN number, as also not following section 73 as illegal, arbitrary, unjust, improper, without jurisdiction and authority of law passed in contravention of the provisions of the GST Act 2017 and also contrary to the judgment of the Hon’ble Supreme Court in the case of Pradeep Goyal Vs.Union of India (UOI) and Ors reported in (2022) 93 GST 378 (SC) and the Allahabad High Court reported in 2024 (85) GSTL 434 violative of articles 14, 19(1)(g) 21, 265 and 300-A of the Constitution of India and consequently to set aside the lA NO: 1 OF 2025 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 grant stay of collection of tax as levied pursuant to the impugned endorsement passed by the 3rd Respondent -Appellate Authority dated 24-04-2025 in A.O. No. DIN3723042521818 in Spl. Apl. No. 322, 323, 324 & 325 /2024-25/CTR and also the orders passed by the 1st Respondent - Deputy Assistant Commissioner (ST)-1, Gudur Circle dated 10-10-2023 for 2017-18, 09-10-2023 for 2020-21, 10-10-2023 for 2021-22 and 10-10-2023 for 2022-23 pending disposal of the writ petition. same. Counsel for the Petitioner: M V J K KUMAR Counsel for the Respondent Nos. 1, 2, 3 & 5: GP FOR COMMERCIAL TAX Counsel for the Respondent No.4: ADDITIONAL SOLICITOR GENERAL OF INDIA

The Court made the following order:

‘5 APHC010285672025 IN THE HIGH COURT OF ANDHRA AT AMARAVATI (Special Original Juri iction) si® PRADESH [3541] WEDNE AY, THE TWENTY FIFTH day OF JUNE TWO THOUSAND AND TWENTY FIVE PRESENT the honourable SRI JUSTICE the honourable smt justice sumathi WRIT PETITION NO: 1449l/?n9<; R RAGHUNANDAN RAO JAGADAIVI Between: A Chandraiah -.petitioner AND Appellate Authority and Additional Commissioner And Others Counsel for the Petitioner: 1.M VJ K KUMAR Counsel for the Respondent(S): 1.GP FOR COMMERCIAL TAX .-RESPONDENT(S)

2.

The Court made the following Order: (perHon’ble Sri Justice R. Raghunandan Rao) The petitioner herein, which is registered under the GST Act, was 10.10.2023, 09.10.2023, 2020-21, 2021-22 subjected to various orders of assessments, dated 10.10.2023 and 10.10.2023 for the tax periods 2017-18 and 2022-23 respectively. An appeal filed against the said orders came to be 2 RRR, J & JS, J”* W.P.N0.14491 of 2025 rejected, on the ground that, the appeal has been filed beyond the period of limitation provided for filing of such appeal. Aggrieved by the orders of assessments, the petitioner has approached this Court, on the ground that, the orders of assessments do not 2. contain 9 DIN number. The question of the effect of non-inclusion of DIN number proceedings, under the G.S.T. Act, came to be considered by the Hon’ble Supreme Court in the case of Pradeep Goya! Vs. Union of India & Ors\ The Hon’ble Supreme Court, after noticing the provisions of the Act and the circular issued by the Central Board of Indirect Taxes and Customs (herein referred to as ‘V.B.I.C.”), had held that an order, which does not contain a DIN number would be non-est and invalid. 3. on Learned Government Pleader for Commercial Tax, would contend that the petitioner having availed the remedy of appeal and having failed in the said appeal, cannot be permitted to challenge the orders of assessments.

4.

A Division Bench of this Court, in its order, dated 18.12.2023, in W.P.No.31675 of 2023, had held, in similar circumstances that a challenge to the original order would be maintainable even if the appeal has been disposed 5. of. ^ 2022 (63) G.S.T.L. 286 (SC)

3 RRR, J&JS,J W.P.No.14491 of 2025 Following the said Judgment, this Writ Petition is allowed setting aside the impugned orders, dated 10.10.2023, 09.10.2023, 10.10.2023 and 10.10.2023, for the tax periods 2017-18, 2020-21, 2021-22 and 2022-23 respectively, and remanding the matter back to the Assessing Officer, for passing fresh orders in accordance with law. Needless to say, the period from the date of the impugned assessment orders, till the date of receipt of this order shall be excluded for the purposes of limitation. There shall be no order 6. as to costs. As a sequel, interlocutory applications pending, if any shall stand closed. SHAIK WIOHD RAH assistant registrar //// ICER To,

1.

The Additional Commissioner (ST) and Appellate Authority, Tirupati, Tirupati District, Andhra Pradesh.

2.

The Deputy Assistant Commissioner (ST)-1, O/o. Commissioner (ST), Gudur Circle, Andhra Pradesh.

3.

The Assistant Commissioner (ST), Gudur Circle, Gudur, SPSR Nellore District Andhra Pradesh.

4.

The Secretary, Union of India, Ministry of Finance, New Delhi -110001. 5. The Principal Secretary, Revenue (CT) Department, Velagapudi, Amaravathi, Guntur District, Andhra Pradesh.

6.

One CC to Sri M V J K Kumar, Advocate [OPUC]

7.

Two CCs to GP for Commercial Tax, High Court of Andhra Pradesh [OUT]

8.

One CC to O/o. Assistant Solicitor General of India, High Court Andhra Pradesh. [OPUC]

9.

Two CD Copies Assistant Gudur, SPSR Nellore District, of TF

HIGH COURT DATED:25/06/2025 ORDER WP NO. 14491 OF 2025 ALLOWING THE W.P., WITHOUT COSTS

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