Pudiparthy Mallikarjuna Reddy vs. The State Of Andhra Pradesh

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WP/8669/2025HC Andhra PradeshGSTCNR APHC01016749202501 April 2025Bench: R RAGHUNANDAN RAO,K MANMADHA RAO7 pages
For Petitioner: SRI. KAMBHAMPATI RAMESH BABUFor Respondent: GP FOR COMMERCIAL TAX

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Cause title — parties, addresses and appearances
[ 352y I IN THE HIGH COURT OF ANDHRA PRADESH :: AMARAVATI (Special Original Jurisdiction) WEDNESDAY ,THE SECOND DAY OF APRIL TWO THOUSAND AND TWENTY FIVE PRESENT „ THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO^ f/SW% DC %4M % m AND THE HONOURABLE DR JUSTICE K MANMADHA RAO WRIT PETITION NO: 8669 OF 2025 Between: Pudiparthy Mallikarjuna Reddy, S/o. Nagi Reddy, Age 49 years, R/o. Main Road, Chintavaram Ponnavolu Nellore, Andhra Pradesh. ...PETITIONER AND 1. The State of Andhra Pradesh, Rep by its Principal Secretary Revenue (CT) Department Velagapudi, Amaravti, Guntur District. 2. The Chief Commissioner of Sales Tax, Government of Andhra Pradesh Kunchanapalli, Guntur District. 3. The Additional Commissioner, Sales Tax (Appeal) Tirupati, Tirupati District. 4. The Assistant Commissioner (ST), Gudur Circle, Gudur, Tirupati District. ...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, more particularly one in the nature of WRIT OF MANDAMUS declaring the action of the 4*^ Respondent in issuing the unsigned and without DIN Number Notice dated 28.10.2024, and Order in Form GST ASMT - 13 vide Notice Reference No. 37AZBPP1557H1Z9 dated 01.03.2025 passed by the 4th respondent without DIN Number as void, non-est in the eyes of law, contrary to the Article 19(1)(g) of the Constitution of India, without jurisdiction and consequently set aside the same in the interest of justice 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 SUSPEND the Order in Form GST ASMT - 13 vide Notice Reference No. 37AZBPP1557H1Z9 dated 01.03.2025 passed by the 4'^ respondent, pending disposal of the present Writ Petition. Counsel for the Petitioner: SRI. KAMBHAMPATI RAMESH BABU Counsel for the Respondents: GP FOR COMMERCIAL TAX

The Court made the following order:

APHC010167492025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) [3525] lK.*- WEDNE AY, THE SECOND DAY OF APRIL TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE DR JUSTICE K MANMADHA RAO WRIT PETITION NO: 8669/2025 Between: Pudiparthy Mallikarjuna Reddy, ...PETITIONER AND The State Of Andhra Pradesh and Others ...RESPONDENT(S) Counsel for the Petitioner: 1.KAMBHAMPATI RAMESH BABU Counsel for the Respondent{S): 1.GP FOR COMMERCIAL TAX The Court made the following order: (perHon’ble Sri Justice R. Raghunandan Rao) The petitioner was served with an assessment order, dated 01.03.2025, passed by the respondent, under the Goods and Service Tax Act, 2017 [for short “the GST Act”], for the year 2024. This assessment order of the 4‘^ respondent has been challenged by the petitioner in this writ petition.

RRR, J & Dr. KMR, J ^

2.

This assessment order is challenged by the petitioner, on various grounds, including the ground that the said proceedings did not contain a DIN number.

3.

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

4.5.

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 d- Rm, J & Dr. KMR, J Deputy Commissioner, Special Circle, Visakhapatnam^ had also held that non-mention of a DIN number would require the order to be set aside. In view of the aforesaid judgments and the circular issued by the C.B.I.C., the non-mention of a DIN number in the order, which was uploaded in the portal, requires the impugned order to be set aside.

6.

Accordingly, this Writ Petition is disposed of, setting aside the impugned proceedings, dated 01.03.2025, issued by the 4^^ respondent, with liberty to the 4*'" respondent to conduct fresh assessment, after giving notice to the petitioner and assigning a DIN number to the said order. The period from the date of the impugned assessment order, till the date of receipt of this order shall be excluded for the purposes of limitation. There shall be no order as to 7. costs. As a sequel, pending miscellaneous applications, if any, shall stand closed. / A. VENU GOPAL RAO ASSISTANT REGISTRAR //// SECTION OFFICER To 1. The Principal Secretary, The State of Andhra Pradesh, Revenue(CT) Department, Secretariat, Velagapudi, Amaravati, Guntur District.(by SPECIAL MESSENGER)

2.

The Chief Commissioner of Sales Tax, Government of Andhra Pradesh Kunchanapalli, Guntur District. ^ 2024 (88) G.S.T.L. 303 (A.P.)

3.

The Additional Commissioner, Sales Tax (Appeal) Tirupati, Tirupati District. The Assistant Commissioner (ST), Gudur Circle, Gudur, Tirupati District.(Nos. 2 to 4 by RPAD) One CC to SRI. KAMBHAMPATI RAMESH BABU Advocate [OPUC] Two CCS to GP FOR COMMERCIAL TAX ,High Court Of Andhra Pradesh. [OUT] Three CD Copies. 4. 5. 6. 7. psk

HIGH COURT DATED:02/04/2025 ORDER WP.No.8669 of 2025 iS ,-y^ •• 10 SEP 2025 Jg) rrentSecti^^ it DISPOSING THE WRIT PETITION WITH NO 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.