Mithra Motors Private Limited vs. The State Of Andhra Pradesh

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WP/6856/2025HC Andhra PradeshGSTCNR APHC01013473202518 March 2025Bench: R RAGHUNANDAN RAO,K MANMADHA RAO6 pages

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Cause title — parties, addresses and appearances
> IN THE HIGH COURT OF ANDHRA PRADESH :: AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE NINETEENTH DAY OF MARCH TWO THOUSAND AND TWENTY FIVE /[o {fff 11 > PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN V 2^ 'f' I AND THE HONOURABLE DR JUSTICE K MANMADHA RAO WRIT PETITION NO: 6856 OF 2025 Between: Mithra Motors Private Limited, Rep by its Director Maganti Madhusudhana Sharma GSTIN; 37AAHCM3735E1ZI Having registered office at 36-26- 126/11, 1®* Floor, Opp: BSNL Bhavan, Eluru Road, Vijayawada. ...PETITIONER AND 1. The State of Andhra Pradesh, Rep by its Principal Secretary, Revenue (CT) Department Velagapudi, Amaravti. 2. Assistant Commissioner ($T), Governorpet Circle, Vijayawada. ...RESPONDENTS Petition under Article 226 of the Constitution of India is filed 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 WRIT OF MANDAMUS declaring the impugned unsigned and without DIN Summary of Order vide Form GST DRC-07 and dated 20.12.2023 as being as illegal, arbitrary, violative of the provisions of GST Act 2017, 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 lA NO: 1 OF 2025 Petition under Section 151 CPC is filed praying that in the circumstances stated in the affidavit filed in support of the petition, the 4 Mm High Court may be pleased to STAY the operation of impugned unsigned j GST DRC-07 and dated and without DIN Summary of Order vide Form 20:^.2023 pending disposal of the C^punsel for the Petitioner :SRI. present Writ Petition. T V P SAI VIHARI Counsel for the Respondent No’s. 1 & 2: GP FOR COMMERCIAL TAX

The Court made the following ORDER: ' it-

APHC010134732025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) [3525] WEDNE AY, THE NINETEENTH 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: 6856/2025 Between: Mithra Motors Private Limited ...PETITIONER AND ...RESPONDENT(S) The State Of Andhra Pradesh and Others Counsel for the Petitioner: 1.TVPSAI VIHARI Counsel for the Respondent(S): 1.GP FOR COMMERCIAL TAX The Court made the following Order: (per Hon't/eSn justice R.RaghunandanRaoJ The petitioner was served with the assessment order, in Form GST DRC-07, dated 20.12.2023, passed by the 2'^^ respondent, under the Goods and Service Tax Act, 2017 [for short “the GST Act”], for the period 2017-18. This order has been challenged by the petitioner in the present Writ Petition. This assessment order, in Form GST DRC-07, Sections-160 & 169 of the Central Goods 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. Commissioner ST & ors, in W.P.No.5238 of 2024, following the aforesaid two Judgments, had held that the absence of the signature of the assessing officer, on the assessment order, would render the assessment order invalid and set aside the said order.

5.

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 Goyal 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-esf and invalid. 6. ^ 2022,(63) G.S.T.L. 286 (SC)

3 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-G$T, issued by the C.B.I.C., had held that non-mention Deputy Commissioner, Special Circle, Visakhapatnam^, had also held that non-mention of a DIN number would require the order to be set aside.

7.

In view of the aforesaid judgments and the circular issued by the C.B.I.C., the non-mention of a DIN number and absence of the signature of the assessing officer, in the impugned assessment order would have to be set aside.

8.

Accordingly, this Writ Petition is disposed of setting aside the assessment order, in Form GST DRC-07, dated 20.12.2023, passed by the 2^^ respondent, with liberty to the 2 assessment, after giving notice and by assigning a signature and 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. 9. nd respondent to conduct fresh J 2024(88) G.S.T.L 179 (A.P.) ^2024 (88) G.S.T.L. 303 (A.P.) SHAIK MOWD RAFf ASSISTANT REJ^TRAR //// SECTION OFFICER To,

1.

The Principal Secretary Revenue (CT) Department, Pradesh, Velagapudi, Amaravti.

2.

The Assistant Commissioner (ST), Governorpet Circle, Vijayawada

3.

One CC to SRI. T V P SAI VIHARI, Advocate [OPUC]

4.

Two CCs to GP FOR COMMERCIAL TAX, Pradesh. [OUT]

5.

Three CD Copies State of Andhra High Court Of Andhra PRK

HIGH COURT DATED:19/03/2025 ORDER WP.No.6856 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.