M/S Dott Srk Joint Venture vs. Assistant Commissioner

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WP/13595/2025HC Andhra PradeshGSTCNR APHC01027486202517 June 2025Bench: R RAGHUNANDAN RAO,SUMATHI JAGADAM6 pages
For Petitioner: SRI

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Cause title — parties, addresses and appearances
' % IN THE HIGH COURT OF ANDHRA PRADESH :: AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE EIGHTEENTH DAY OF JUNE TWO THOUSANDAND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO AND THE HONOURABLE SMT JUSTICE SUMATHI JAGADAM WRIT PETITION NO: 13595 OF 2025 Between: M/s. DOTT-SRK Joint Venture, (Represented by its Chief General Manager) D. No. 1/493/A, Smith Road, YSR Kadapa, Andhra Pradesh- 516001 ...PETITIONER AND 1. Assistant Commissioner(ST), Kadapa-1 Circle, Kadapa, Andhra Pradesh 2. State of Andhra Pradesh, rep. by its Secretary (Revenue), Secretariat Velagapudi, Andhra Pradesh- 52228 ...RESPONDENTS Petition under Article 226 of the Constitution of India praying that in the circumstances stated in the affidavit filed therewith, the High Court be pleased to issue a Writ of Mandamus or any other appropriate writ or order or direction by setting aside the impugned Show Cause Notice dt. may 07.11.2024 issued in Form DRC-01 along with summary of Show Cause Notices issued in Form GST DRC-01 vide Ref. No.ZD37112400632^ 07.11.2024 for the period 2018-19, 07.11.2024 for the period 2019-20, dt. Ref. No.ZD37112400633^Ydt. Ref. No.ZD371124006336Qdt. 07.11.2024 for the period 2020-21 and Ref. No.ZD371124006346Pdt. 07.11.2024 for the period 2021-22 and consequent impugned order passed in Form DRC-07 dt. 17.01.2025(sic. 17.01.2024) along with Summary of Orders in Form DRC-07 vide Ref. No. r ^018-19,Ref. No. ZD370125021386L for ZD370125021366N for the period 2020-21 ZD3701250214003 for the period the period 2019-20, Ref. No. and Ref. No. ZD370125021341Z for the period 2021-22 confirming the demand of Rs. 13,91,41,364/- (COST 6,95,70,682/-) and interest of Rs. of Rs. 6,95,70,682/- and SGST of Rs. 21,96,12,125/- issued by the 1 Respondent without having any signatures non-est in law. as being illegal, arbitrary, and IA NO: 1 OF 909 Petition under Section 151 CPC stated in the affidavit filed in praying that in the circumstances support of the petition, the High Court may be notice dt. 28.04.2025 issued to the bank pleased to set aside the garnishee of SRK Construction and Projects Pvt f garnishee noticedt.06.05.2025 to M/s National ! Development Corporation, in the name of the said direct the 1^^ Respondent to withdraw the lA NO: 2 OF 207.^ Ltd, partner in the petitioner JV.and Highway and Infrastructure company as illegal and garnishee notice. Petition under Section 151 stated in the affidavit filed in support of the petition, the High Court may be pleased to grant stay of all further CPC praying that in the circumstances proceedings pursuant to the impugned order passed in Form DRC-07 dt.17.01.2025(sic Summary of Orders in Form DRC-07 vide Ref. No. the period 2018-19, Ref. No. ■17.01.2024) along with ZD3701250214003 for ZD370125021386L for the period 2019-20, Ref. NO.ZD370125021366N ZD370125021341Z for the for the period 2020-21 and Ref. No. period 2021-22 confirming the demand of Rs. 682/- and SGST of Rs.6,95,70,682/-) - pending disposal of the Writ Petition 13,91,41,364/- (CGST of Rs.6,95,70 and interest of Rs. 21,96,12 125/ as otherwise the Petitioner will be put to Counsel for the Petitioner: SRI Counsel for the Respondent Nos.

The Court made the following: ORDER severe loss and hardship. Y. SREENIVASA REDDY 1 & 2: GP FOR COMMERCIAL TAX

APHC010274862025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) [3541] I n. WEDNE AY, THE EIGHTEENTH DAY OF JUNE TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SMT JUSTICE SUMATHI JAGADAM WRIT PETITION NO: 13595/2025 getween: 5 Dott Srk Joint Venture ...PETITIONER K n I ivi/ AND yi^ssistant Commissioner and Others Counsel for the Petitioner: 1.YSREENIVASA REDDY Counsel for the Respondent(S): 1.GP FOR COMMERCIAL TAX 1-he Court made the following Order: (per Hon’ble Sri Justice R. Raghunandan Rao) The petitioner was served with the impugned show-cause notice and along with summary of show-cause notices, in Form GST DRC-01, dated Q7.11.2024 and the assessment order and along with summary orders, in Form OST DRC-07, dated 17.01.2025, passed by the 1®* respondent, under the Goods and Service Tax Act, 2017 [for short “the GST Act”], for the period from 2021-2022. These impugned show-cause notices and the assessment orders of the 1®‘ respondent have been challenged by the petitioner in this Writ petition. ...RESPONDENT(S)

2 >si

2.

These orders, in Form GST DRC-01& 07, petitioner, on various grounds, including the do not contain the signature of the assessing officer. Learned Government Pleader instructions, submits that there i* Sections-160 & 169 of the Central Goods provisions of and Service Tax Act, 2017, would not rectify such a defect. Following this Judgment, another Division Bench of this Court, in the case of M/s. M/s. SRS Traders 19.03.2024, Commissioner ST & Vs The. Assistant in W.P.No.5238 of 2024, following the aforesaid ors two Judgments, had held that the absence of the sisignature of the assessing ! assessment order invalid officer, on the assessment order, would render the and set aside the said order.

6.

Following the aforesaid Judgments, the impugned assessment orders would have to be set aside on account of the absence of the signature of the assessing officer, on the impugned orders.

7.

Accordingly, this Writ Petition is disposed of setting aside the impugned show-cause notice and along with summary of show in Form GST DRC-01, dated 07.11.2024 and the -cause notices, assessment order and along WiW summary orders, in Form GST DRC-07, dated 17.01.2025, passed by the 3 respondent, with liberty to the respondent to conduct fresh assessment, after giving notice and by assigning a signature to the said orders. The period from the date of the impugned orders, till the date of receipt of these Orders shall be excluded for the purposes of limitation. There shall be no order as to costs. As a sequel, pending miscellaneous applications, if any, shall stand closed. I A. VENU GOPAL RAO ASSISTANT REGISTRAR //// ^/■v/ SECTION OFFICER To 1. The Assistant Commissioner (ST), Kadapa-1 Circle, Kadapa Andhra Pradesh

2.

The Secretary (Revenue), State of Andhra Pradesh, Secretariat, Velagapudi, Andhra Pradesh- 52228

3.

One CG to Sri Y. Sreenivasa Reddy, Advocate [OPUC]

4.

Tw6%Cs to GP for Commercial Tax, High Court of Andhra Pradesh. [OUT]"

5.

Three CD Cdpies. ssb

HIGH COURT DATED:18/06/2025 ORDER WP.No. 13595 of 2025 IS OCT 2025 )W Qurreni ’iE/S.S DISPOSING OF 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.