M/S Syed Aafiya Steel Traders vs. Dy.Assistant Commissioner(St)-1

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WP/7055/2025HC Andhra PradeshGSTCNR APHC01013177202525 March 2025Bench: R RAGHUNANDAN RAO,K MANMADHA RAO6 pages
For Respondent: GP FOR COMMERCIAL TAX

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Cause title — parties, addresses and appearances
I IN THE HIGH COURT OF ANDHRA PRADESH :: AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE TWENTY SIXTH DAY OF MARCH ^ TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R. RAGHUNANDAN RA^^V^^S AND THE HONOURABLE DR JUSTICE K. MANMADHA RAO WRIT PETITION NO: 7055 OF 2025 & oo Between; M/s. Sy^ Aafiya Steel Traders, Represented by the proprietor Sri Syed Moosa Door No 43-10-183, Old 8-28-147, Plot No 163, Phase-1 11 Autonagar, Guntur, Andhra Pradesh PIN 522201. ...PETITIONER AND 1. Dy.Assistant Commissioner(ST)-1, O/o. The Assistant Commissioner(ST) Kothapet Circle, Guntur-ll Division, Guntur, A.P. PIN 522 001. 2. State of Andhra Pradesh, Represented by the Secretary to Government of A.P. Revenue (CT) Department, Government of A.P. Secretariat Velagapudi, Mangalagiri Mandal, Guntur District, AP, PIN - 522 503. ...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 an appropriate writ, order or direction, more in the nature of Writ of Mandamus, setting aside the impugned said Intimation of Tax Ascertained dated 22-06-2024, the show-cause Notice and its summary dated 27- 07-2024 and the 3 personal hearing Notices dated 11-09-2024, 21-09-2024 and 05- 11-2024 and the orders and its summary dated 04-12- 2024. may lA NO: 1 OF 2025 Petition under Section 151 CPC praying that in the circumstances jstated in the affidavit filed in support of the writ petition, the High Court may 'be pleased to suspend the said impugned communications with immediate effect for the above detailed reasons; and to pass such other order or orders in the interest of Justice, lest the petitioner will be put to irreparable economic loss. Balance of convenience is clearly in favour of the petitioner and against the Respondents. Counsel for the Petitioner : SRI J.N VENKATA SURESH KUMAR Counsel for the Respondents: GP FOR COMMERCIAL TAX

The Court made the following: ORDER

APHC010131772025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) [3525] ¥• WEDNE AY, THE TWENTY SIXTH DAY OF MARCH TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE DR JUSTICE K MANMADHA RAO WRIT PETITION NO: 7055/2025 Between: ...PETITIONER M/s Syed Aafiya Steel Traders AND ...RESPONDENT(S) Dy Assistant Commissionersti and Others Counsel for the Petitioner: 1.J,N VENKATA SURESH KUMAR Counsel for the Respondent(S):

1.

The Court made the following order: (perHon’ble Sri Justice R. Raghunandan Rag) The petitioner was served with an assessment order, under FORM GST DRC - 01A, dated 22.06.2024, passed by the 1®' respondent, under the Goods and Services Tax Act, 2017 [for short “the GST Act”], for the tax period 2020-2021 to 2023-2024. This assessment order of the 1®^ respondent has been challenged by the petitioner in this Writ Petition.

2 RRR,J & Dr.KMR;2 W.P.No.7055of2025

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 4. 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 ^ 2022 (63) G.S.T.L. 286 (SC) "2024(88)G.S.T.L. 179 (A.P.)

3 RRR,J & Dr.KMR,J W.P.No.7055 of 2025 Deputy Commissioner, Special Circle, Visakhapatnam\ had also held that non-mention of a DIN number would require the order to be set aside.

6.

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 in the portal, requires the impugned order to be was uploaded set aside.

7.

Accordingly, this Writ Petition is disposed of, setting aside the impugned proceedings, dated 22.06.2024, issued by the 1 liberty to the respondent to conduct fresh St respondent, with 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 costs. As a sequel, pending miscellaneous applications if any, shall stand closed. ""4024 (88)G.S.Y.L. 303 (A.P.) . P.U.V.BHASKAR RAO assistant REGISTRAR SECTION OFFICER //// To,

1.

The Dy.Assistant Commissioner(ST)-1, O/o The Assistant Circle, Guntur-ll Division, Guntur Government of A.P. Revenue (CT) Department Government of A.P. < 522^503 Mangalagiri Mandal, Guntur District

3.

One CC to Sri J.N Venkata Suresh Kumar, Advocate [OPUC] OOUT^^^ Commercial Tax, High Court of Andhra

5.

Three C.D. Copies. A.P. PIN State Secretariat , AP, PIN - Pradesh.

HIGH COURT DATED:26/03/2025 ORDER WP.No.7055 of 2025 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.