M/S Om Sai Professional Detective And Security Services Private Limited vs. The Assistant Commissioner(St)

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WP/2939/2025HC Andhra PradeshGSTCNR APHC01005343202511 February 2025Bench: R RAGHUNANDAN RAO,HARINATH.N6 pages
For Petitioner: SRI. M NAGA DEEPAKFor Respondent: GP FOR COMMERCIAL TAX

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Cause title — parties, addresses and appearances
a h IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Jurisdiction) WEDNESDAY, THE TWELFTH DAY OF FEBRUARY TWO THOUSAND AND TWENTY FIVE PRESENT HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO AND HONOURABLE SRI JUSTICE HARINATH.N WRIT PETITION NO: 2939 OF 2025 Between; M/s Om Sai Professional Detective And Security Services Private Limited, A Company having office at D.No.57-3-4, Sri Rama Nilayam, Yadavula Bazar, Patamata, Vijayawada, Krishna, Andhra Pradesh - 520010 ...Petitioner AND The Assistant Commissioner (ST), Autonagar, Vijayawada II, Andhra Pradesh ...Respondent Petition under Articie 226 of the Constitution of india is filed praying that in the circumstances stated in the affidavit fiied therewith, the High Court may be pleased to issue a writ, order or direction more particularly in the nature of a writ of mandamus declaring the Show Cause Notice in Form No. DRC-01 bearing Ref No. ZD370124021739E dated and its consequent order under Section 73 dated 30-01-2024 24-04-2024 bearing passed by the Respondent for the financial year 2018-19 as being void, illegal, arbitrary without jurisdiction and non est in the eye of law and consequently set aside the Reference No. ZD3704240227587 same. p 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 writ petition, the High Court may be pleased to stay all further action including collection of tax pursuant to the Show Cause Notice in Form No. DRC-01 bearing Ref No. ZD370124021739E dated 30-01-2024 and its consequent order under Section 73 dated 24-04-2024 bearing Reference No. ZD370424022758 7. Counsel for the Petitioner: SRI. M NAGA DEEPAK Counsel for the Respondent: GP FOR COMMERCIAL TAX

The Court made the following: ORDER

APHC010053432025 IN THE HIGH COURT OF ANDHRA PRADESH AT AMARAVATI (Special Original Juri iction) [3488] > WEDNE AY ,THE TWELFTH DAY OF FEBRUARY TWO THOUSAND AND TWENTY FIVE PRESENT THE HONOURABLE SRI JUSTICE R RAGHUNANDAN RAO THE HONOURABLE SRI JUSTICE HARINATH.N WRIT PETITION NO: 2939/2025 Between: M/s Om Sai Professional Detective And Security Services Private Limited ...PETITIONER AND The Assistant Commissionerst ...RESPONDENT Counsel for the Petitioner: 1.M NAGA DEEPAK Counsel for the Respondent:

1.

GP FOR COMMERCIAL TAX The Court made the following order: (perHon’ble Sri Justice R. Raghunandan Rao) The petitioner was served with the show cause notice, in Form No.DRC-01, bearing Ref No.ZD370124021739E, dated 30.01.2024, and the assessment order, in Form GST DRC-07, Ref No.ZD3704240227587, dated 24.04.2024, passed by the respondent, under the Goods and Service Tax Act, 2017 [for short “the GST Act”] for the period of 2018-2019, these orders have been challenged by the petitioner.

2

2.

The show cause notice, in Form No.DRC-01, and the assessment Form GST DRC-07, is challenged by the petitioner, on various the ground that the said proceedings did not contain a DIN order, in grounds, including number. Pleader for Commercial Tax, DIN number on the impugned on Learned Government 3. instructions, submits that there is no assessment orders.

4.

The question of the effect of non-inclusion of DIN number on to be considered by the Hon’ble of Pradeep Goya! Vs. Union of India & Ors\ Court, after noticing the provisions of the Act and the the Central Board of Indirect Taxes and Customs (herein 'C.B.I.C.”), had held that an order, which does not contain a DIN number would be non-est and invalid. proceedings, under the G.S.T. Act, came Supreme Court in the case The Hon’ble Supreme circular issued by referred to as 5. A Division Bench of this Court in the case of M/s. Cluster Enterprises Vs. The Deputy Assistant Commissioner (ST)-2, Kadapa dated 23.12.2019, bearing No. 128/47/2019-GST , on the basis of the circular, 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.)

3 •? 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 6. C.B.I.C., the non-mention of a DIN number in these orders, which was uploaded in the portal, requires the impugned order to be set aside. Accordingly, this Writ Petition is disposed of setting aside the 7. show cause notice, in Form No.DRC-01, bearing Ref No.ZD370124021 739E, dated 30.01.2024, and the assessment order, in Form GST DRC-07, Ref NO.ZD3704240227587, dated 24.04.2024, passed by the respondent, with liberty to the respondent to conduct fresh assessment, after giving notice and by assigning a DIN number to the said order. The period from the date of the impugned assessment orders, till the date of receipt of this Order shall be excluded for the purposes of limitation. There shall be no order as to costs. 2024 (88) G.S.T.U 303 (A.P.) B. CHITTI JOSEPH ASSISTANT REGISTRAR SECTION OFFICER //// To,

1.

The Assistant Commissioner (ST), Autonagar, Vijayawada II, Andhra Pradesh

2.

One CC to SRI. M NAGA DEEPAK, Advocate [OPUC]

3.

Two CCS to GP FOR COMMERCIAL TAX , High Court Of Andhra Pradesh. [OUT]

4.

Three CD Copies csb

HIGH COURT DATED:12/02/2025 ORDER g 16JUN2ft?5 ^ Curtmi SMiion . ■$( WP.No.2939 of 2025 DISPOSING OF THE WP 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.