Mega Steel Industry vs. The Assistant Commissioner

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WP/10458/2025HC Andhra PradeshGSTCNR APHC01019130202529 April 2025Bench: R RAGHUNANDAN RAO,Y. LAKSHMANA RAO6 pages
For Petitioner: SRI SHAIK JEELANI BASHAFor Respondent: GP FOR COMMERCIAL TAX

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Cause title — parties, addresses and appearances
f IN THE HIGH COURT OF ANDHRA PRADESH :: AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE THIRTIETH DAY OF APRIL TWO THOUSAND AND TWENTY FIVE I PRESENT ^ THE HON’BLE SRI JUSTICE R RAGHUNANDAN RAO AND THE HON’BLE DR JUSTICE Y. LAKSHMANA RAO WRIT PETITION NO: 10458 OF 2025 |0 ••• • k Between: M/s. Mega Steel Industryf D. No. 145-1, 146-2B, Gollapuram, megasteelind2@gmail.com HindupQr, Anantapuram Dist, State of Andhra Pradesh. Rep. by its Authorizer..B.Sadiq Bhasha S/o. Shaik Kousar. ...PETITIONER AND 1. The Assistant Commissioner, (ST) (FAC), Hindupur Circle, Complex, D.L.Road, Hindupur-515 201. Anantapuram District, A.P. 2. The Assistant Commissioner (ST), Hindupur, Anantapuram District, A.P. 3. The State of Andhra Pradesh, Rep. its Principal Secretary, r. Department, A.P. Secretariat, Velagapudi, Amaravati. Guntur District Andhra Pradesh. t , Sri Nandi Revenue ...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 Writ of Mandarnus or any other appropriate Writ Order or Direction deciaring the action of the 1st Respondent in passing the Proceedings dated 27.02.2025 by way of Composite Order for both periods for 2018-19 and 2020-21 may or the tax as arbitrary, contrary to law and in and Rule of Law, without jurisdiction, unsigned partially by the proper officer, without DIN violation of Principles of Natural Justice are not valid v' in the eye of law and consequently set aside both the Orders dated 27.02.2025 as null and void. 1 OF 2025 ,;5: i , ■ ij-i. 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 Operation of the both Proceedings dated 27.02.2025 passed for the tax periods 2018-19 and 2020-21, pending disposal of the above Writ Petition, as otherwise, the Petitioner will be put to severe loss and hardship. Counsel for the Petitioner: SRI SHAIK JEELANI BASHA Counsel for the Respondents: GP FOR COMMERCIAL TAX

The Court made the following: ORDER

APHC010191302025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) 050 [3536] 0K^ WEDNE AY, THE THIRTIETH DAY OF APRIL TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE DR JUSTICE Y. LAKSHMANA RAO WRIT PETITION NO: 10458/2025 Between; Mega Steel Industry ...PETITIONER AND The Assistant Commissioner and Others ...RESPONDENT{S) Counsel for the Petitioner: 1.SHAIK JEELANI BASHA Counsel for the Respondent{S); 1 .GP FOR COMMERCIAL TAX

2.

The Court made the following order; (perHon’ble Sri Justice R. Raghunandan Rao) The petitioner was served with an assessment order, in Form GST DRC-07, dated 27.02.2025, passed by the 1®' respondent, under the Goods and Service Tax Act, 2017 [for short “the GST Act”]. This assessment order of the respondent has been challenged by the petitioner in this writ petition.

m W.P.No.l0458of2025 This assessment order is challenged by the petitioner, on various grounds, including the ground that the said proceedings did not contain a DIN 2. number.

3.

Learned Government Pleader for Commercial Tax, on instructions, submits that there is no DIN number on the impugned assessment order.

4.

The question of the effect of non-inclusion of DIN number on 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 “C.B.I.C.”), had held that an order, which does not contain a DIN number would be non-est and invalid.

5.

A Division Bench of this Court in the case of M/s. Cluster Enterprises Vs. The Deputy Assistant Commissioner (ST)-2, Kadapa on the basis of the circular, dated 23.12.2019, bearing No. 128/47/2019-GST, issued by the C.B.I.C., had held that non-mention of a DIN number would \ , '2022(63)G.S.T.L. 286 (SC) ^ 2024 (88) G.S.T.L. 179 (A.P.)

A W.P.No.10458 of 2025 Visakhapatnam^ had also held that require the order to be set aside. Deputy Commissioner, Special Circle, non-mention of a DIN number would

6.

In view of the aforesaid judgments and C.B.I.C., the non-mention of the circular issued by the was uploaded a DIN number in the order, which in the portal, requires the impugned order to be set aside.

7.

Accordingly, this Writ Petition is disposed of, setting aside the impugned proceedings, dated 27.02.2025, issued by the respondent, with liberty to the 1®' respondent to conduct fresh the petitioner and assessment, after giving notice to assigning a DIN number to the said order. The period from the date of the impugned assessment order, fill the date of receipt of this order 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. ^ 2024 (88) G.S.T.L. 303 (A.P.) V DIWAKAR DEPUTY ^^TRAR f; k ^TFtUECOPY// SECTION OFFICER To,

1.

The Assistant Commissioner, (ST) (FAC), Hindupur Circle, Sri Nandi Complex, D.L.Road, Hindupur-515 201. Anantapuram District, A.P. [RPAD]

2.

The Assistant Commissioner (ST), Hindupur, Anantapuram District, A.P.

3.

The State of Andhra Pradesh, Rep. its Principal Secretary, Revenue Department, A.P. Secretariat, Velagapudi, Amaravati. Guntur District, Andhra Pradesh.

4.

One CC to Sri Shaik Jeelani Basha Advocate [OPUC]

5.

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

6.

Three CD Copies TF

HIGH COURT DATED:30/04/2025 ORDER WP.No.10458of2025 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.