Ankit Industries vs. Assistant Commissioner (State Tax)

[ 3446 ] HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (SPecial Original Jurisdiction) THURSDAY, THE NINETEENTH DAY OF JUNE TWO THOUSAND AND TWENTY FIVE PRESENT THE HON'BLE THE ACTING CHIEF JUSTICE SUJOY PAUL AND THE HON'BLE SMT JUSTICE RENUKA YARA 15571 15575 15614 WRIT PETITION Nos.14877 15541 15554 15632 15824 15847 and 15886 ot 2O25 WRIT PETITION NO:14877 0F 2025 Between: M/s. Venkateshwarlu Tanda malla, 25-9-148, Bapuji. Nagar Kazipet, warangal Uiuin, fetangana-506003. Rep by Proprietor, T Venkeshwarlu' AND 1 ...PETITIONER The Assistant Commissioner (ST)' Warangal Urban 1' Warangal Division' Telangana. 2. Union of lndia, ReP Block, New Delhi. State of Telangana, Rep. by its Principal Secretary to Government' Revenue (CT-ll) Departrient. Secretariat, Hyderabad ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleasedtoissueanappropriateWrit,orderorDirectionmoreparticularlyinthe nature of MANDAMUS declaring the action of the 1't Respondent in passing the impugnedorderdatedl4lo}t2o24passedfortheyear2ol9.2o20,asimproper' illegal, contrary to facts and unsigned and consequently set aside the same' by the Secretary, Ministry of Finance, No'136-A, North J f lA NO: 1 OF 2025 Petition Lr.rdr;r Section 151 CPC praying that in the circutnstances stated in the affidavit 'iled rr support of the petition, the High ()ourt mey be pleased to grant stay of corle:ction of the total disputed tax of Rs.4 65,1LB1l SGST and Rs. 4,65,2811- CGS-- a,rrl penalty of Rs. 46,528/- CGST and Rs. ,46,528/- SGST. Counsel for ther Pel:itioner: SRI EPPA RAKESH REDDY Counsel for the Rerspondents No.1 & 3: SRI SWAROOP OORILLA, SPECIAL GOVERNMENT PLEADER FOR STATE TAX Counsel for the Ferspondent No.2: SRI GADI PRAVEEN KUMAR DEPUry SOLICITOR GF:NERAL OF INDIA WRIT PETITION NO: 15541 OF 2025 Between M/s. South ="., 6 r,'qr.prises, 4'h Floor, Plot No.51,52, Prashanti Nagar, Kukatpally, Rangareddy, Hyderr:rbad, Telangana-500072, Rep.by its Proprietor lahul Raj Kumar Reddy Madithatr .,.PETITIONER AND 1 2 3 The Assrstarn: Oommissioner of State Tax (Enforcernent), E rforcement wing, O/o Chir:f C ommissionerate of State Tax, Conrmercial Taxes Building, Nampally, l-lyderabad - 500004. The Comn issirrner of State Tax, Government of Telangirna Commercial Taxes bu i1,l irr3, Nampally, Hyderabad. The State o' ''elangana, Rep. by its Principal Secretary to Government, Revenue Cil - l) Department, Secretariat, Hyderabad ..,RESPONDENTS Petition ,r.rC:rr Article 226 ol lhe Constitution of lndia pr;rying that in the circumstances r;t:t:: in the affidavit filed therewith, the Higi Court may be pleased to issr-t: an tppropriate Writ, Order or Directior, mcre particularly in the nature of MANDl.l\rlt.JS declaring the action of the 1't re,sponderrt in passing the impugned order d;r'ed 2410812024 for the Financial \tea( 20 9-20 as illegal, arbitrary, high-ha,n1ed, without authority of law and iurrsdiction, barred by limitation, and in yic,lation of the principles of natural justir;e and n tnest in law as it did not contar. th€ physical or digital signature of the 1'r respondent and hopelessly time bitrl)d and set aside the same. ) 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 grant stay of all further proceedings including any recovery proceedings through coercive measures by the '1't respondent in pursuance of the impugned order passed dated 24t0812024 for the financi al year 2019-20 pending disposal of this Writ Petition. Counsel for the Petitioner: SRI V' SIDDHARTH REDDY Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVERNMENT PLEADER FOR STATE TAX WR]T PETITION NO:15554 0F 2025 AND 1 Between: M/s.AmbikaBioKare,APartnershipfirm,PlotNo.8-2-603,RoadNo',10'Banjara i]iri., ivo"rrnja, t"t"ng"ni - soodai R6presented. by its partner and Authorized Sil;;i;il-G;[iiu 5irr"ruiv"n"5io.-rlroiiir,i-r',t,'tnv'ng"d about 38 Years occ' Business ..,PETITIONER The Assistant Commissioner of State Tax, Jubilee Hills -1 ' Punjagutta' Hyderabad Telangana Commissioner of Commercial Taxes, State of Telangana, C'T' Complex' Nampally, Hyderabad- 50000 1 State of Telanqana, Through Principal Secretary to Government Revenue Department (Cdmmercial Tax), Hyderabad, Telangana HDFC Bank, Address, No 4/89/G/A/B/1A, S9I' Resider-cy' - NH .7' pJtti'.n".iJdro, Opposite diwan Dhaba Medchal Malkajgiri - 500055 Rep by its Manager Union Bank, Jayabheri park road kompally, H 3-99, nh-7, Nagpur highway' Kompally, Telangana 500014 Rep by its Manager ..,RESPONDENTS 2 J 4 5 Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High Court may be pleased to pass a writ order or direction, more particularly in the nature of a writ of mandamus declaring the show cause Notice dated 30-05-2022 bearing Ref No' 2D36o52201g186J(AnnexureP2)anditsconsequentorderbearingReference + No. 2D360424C4t5147 (Annexure Pl) dated 23-04-202,+ for the Financial Year 2018-19 and Conserlrent Bank attachment notice dated 2,1-05-2025 as being void, illegal, arbitrary, viclat ve of Articles 14, 19,21 and 265 of the lonr;titution of lndia, violative of prirrcipr es of natural justice, and without author ty of law and consequently se't ers cle the same. lA NO: 1 OF 2025 Petition unce- fiection 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High C)urt ma', be pleased to suspend the opr:rerticn of the Bank Attachment lssued in F orm GS I DRC 13 dated 24-05-2025 by tt^e Flespondent No, 1 to Respondent No. [' Bank lA NO: 2 OF 2025 Petition rrncler Section 151 CPC praying that in the circumstances stated in the affidavit filerj in support of the petition, the High Courl may be pleased to stay all further actio. n,) rrding collection of tax pursuant to the Sho,rv Cause Notice dated 30-05-20112 cearing Ref No. 2D360522019186J (Annex re P2) and its consequent Orcer L;earing Reference No. 2D360424C485567 (Annexure Pl) dated 23-04-20',t-4 Counsel for the Petitioner: SRI M. NAGA DEEPAK Counsel for the Rer;oondents No.1 to 3: SRI SWAROOP OORILt A, SPECIAL GOVERNMENT PLEADER FOR ST/\TE TAX Counsel for ther Rer;oondent No.4 & 5: - 5 WRIT PETITION NO:15 571 0F 2025 Between: AND 1 Ankit lndustries, Plot no 183, S.no 2g2,299.301' 3.02 Ram Reddy N"9{, BLSe iiil;v'Di-.i;i;i, ic-*p by it; k;,rt;i'nur ur. Ashok Kumar As'anrual s/o rrilok Chand Agarwal R/o HYderabad. ...PETITIONER AssistantCommissioner(StateTax),Jeedimetla-2Circle,HyderabadRural Division Gagan Vihar, Nampally, Hyderabad' Joint Commissioner (ST), Hyderabad Rural Division, Gagan Vihar' Nampally' Hyderabad Commissioner of State Goods Service Taxes, 1"t Floor, Commissioner.of Corr"ri"f Taxes guifOing-' - Government of Telangana' Nampally' Hyderabad. The State of Telangana, rep. by its Principal Secretary, Revenue (State Tax) Department, Secretariat, Hyderabad ...RESPONDENTS 2 J 4 Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue Writ of Mandamus or any other appropriate writ order or direction under Article 226 of lhe Constitution of lndia in declaring (1) unsigned show cause notice dt.31i05 12022 tssued by the 1't respondent in not serving the same to the petitioner as Prescribed under the Act and the said show cause notice is cryptic, vague,withoutanyreasonsisquitecontrarytothemandatoryperiodprescribed under section 7 3(2) of the Act, before passing the order, is violative of the Act and unsustainable in the eye of law (2) failure to provide the details or attachment to the unsigned show cause notice dt.31/05 12022 and unsigned oldet dl.23ll8l2o24 issued under section 73 of the Act passed by the 1st respondent under section 73 of the Act, 2017, without signature over the attachment of the details under reference No. 2d3608240922652 for the financial period April, 2019 to March' 2020isviolativeoftheprincipalofnaturaliusticeequity,fairplayandcontraryto lawand(3)theunsignedshowcausenoticedl.3llo'tzo2zandunsignedorder dt.23to8l2o24 issued under section 73 0f the CGST Acl,2017 is violative of Rule 26 of the CGST Rules, 2017 as prescribed under the GST Act' 2017' as arbitrary 6 illegal and quite crrirary to raw consequenfly set as de the same as void, unenforceable a r d ursustainable. lA NO: 1 OF 2025 Petition unrie' section 151 cpc praying that in the circrms ances stated in the affidavit filed n sr- pport of the petition, the High court rnay be lrleased to grant stay of collection ,rf (i sputed tax under the GGST and SGST of Rs.1,5g,01g/_ and penalty levied or Frs;.2D,000i-, passed under section 73 c,f the sosr and GGST 4c1,2017. unde-e'ferrence No. ZD360B 240g226s2 pursuant tc the unsigned order dt.2310812024, iss;ueri by the 1st respondent for the financ ar periorr April, 201g to March 2020 penrling ciisposal of the above writ petition. Counsel for the Pe,titioner: SRI TEJPRAKASH TOSHNIWAL Counsel for the Re,soondents: SRI SWAROOP OORILLA, SPECIAL GOVERNMENT PLEADER FOIt STATE TAX WRIT PETITIONNO: 15575 OF 2O2!; Between: Y/. Lakshmi DLrrg r Granites, Hanumkonda, Te lanqa na-506001' about 65 years. 2-5-636. 2no Floor. Suberiarr. Hanamkonda Rep.by its Partner Mr. C. Santosh Reddy, aged ..PETITlONER AND 1 2 The State -la:< rlfficer, Warangal, Telangana. Assistant C:r: rn rn issioner (ST), Warangal Urban_l Circk:, Wiaran;al. The State :r' Telanoana Rep. by..its. principal Secreta.y Revenue (CT) Department '-,, l,ragaira Secret'ariatl HVOeri'Urd*' -' ...RESPONDENTS Petition unrier A'ticre 226 of the constitution of rnrria r)ray ng that in the circumstances stert.ci in the affidavit fired therewith, ther High )ourt may be pleased to issue rA/rit 'rf l\/andamus or any other appropriate wr it or order or Direction decrarinc thr: action of the 1't and 2nd Respondents ir pas sing the three different orders, dit-er 24 02-202s, 18.02.2025 and 03.02 zo25, rh,= summary of the Orders in Fornr C;Si'r DRC-07, dated 24.02.2025, 18.02,,202i a.td 03.02.2025 and Attachment tc rllil DRC-07, dated 24.022025, 1802202,5 a rd O3.O2.2OZ' 1 passed by the 1"t and 2nd Respondents, levying IGST/CGST/SGST under Section 73 of the IGST/CGST/SGST Acts, 2017, for the same tax period 2020-21, without even issuing Form GST DRC-01A as contemplated under Rule 142(14) of the Rules 2017, without signature of the officer concerned in the summery of the show cause Notice in Form GST DRC-01 daled 25.11.2024 and order under Section 73 dated 28.02.2025, without DIN and not granting sufficient opportunity of being heard to the Petitioner, as arbitrary, contrary to the provisions of the |GST/CGST/SGST Acts 2017 , and contrary to the Article 14 19 (2) (g) 21 and 265 of Constitution of lndia and consequently set-aside the Orders of the 1"t and 2nd Respondents daled 24.02.2025, ',18.O2.2025 and 03.02.2025 for the tax period 2O2O-21 as illegal, without jurisdiction and also the same is null and void lA NO: 1 OF 2025 Petition under section 151 CPC praying that in the circumstances stated in the affidavit filed in support of the petltion, the High court may be pleased to Suspend the Operation of the Orders dated 24.02'2025, 18'02'2025 and 03.02.2025 passed for the tax period 2020-21 by the 1't Respondent under the IGST/CGST/SGST Acts, 2017, 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: SRI SWAROOP OORILLA, SPECIAL GOVERNMENT PLEADER FOR STATE TAX WRIT PETITIO N NO: 15614 OF 2025 tvtis. Clone Deals Private Limited, 5-1}i5n6,4th floor, Jonna ban_da, Secunderabad, ivJeiaOad. Tetanqana 500010 Represented by its Authorized SignaloV Nuruddin SfirnirtOi"'p.t"f, -Slo. Sr'inrOOin patet Aged dbout 43 Years, Occ. Business R/o Hyderabad ...PETITIONER Between: AND 1 2 The Assistant commissioner of State Tax, Malkajgiri N 2, Malkajgiri Division, Hyderabad, Telangana. Commissioner of Commercial Taxes, State of Telangana, C T' Complex' Nampally, Hyderabad- 50000'l 8 State of 1'elargana, Through Principal Secretary lo Government Revenue Departm€,nt (i)rmmercial Tax), Hydeiabad, Telanjana .,.ITESPONDENTS Petition u rder Article 226 ot lhe constitution of lndia pra ying that in the circumstances stertrrrl in the affidavit filed therewith, the Iligh court may be pleased to issue a vr-it. order or direction, more particularly ir the nature of a writ of mandamus d€c a'i.g show cause Notice dated 3i-os-202.1 bearing Reference No. 2D3605240s,36,1,13 along with its attachment and its :onsequ =nt order dated 27-08-2024 bearrng l?eference No. 2D360824 117Z3Bg along wiilr its attachment passed by the Respordent No, 1 as being void, illegal, arbitrary wi hout jurisdiction and non est in th:r e'rt: of law and consequently set aside tre same. 3 lA NO: 1 OF 2025 Petition ur,der Section 15i cpc praying that in the circums-ances stated in the affidavit filec! rr l;uoport of the petition, the High court ma,r be pleased to stay all further action nci -rcing collection of tax pursuant to the order <)ztled 27 -og-2024 bearing Refererce l{c 2D3608241172399 along with its attachrrent passed by the Respondent l{o. '1 . Counsel for the Petitioner: SRI M. NAGA DEEPAK Counsel for the Rr:sprondents: SRI SWAROOP OORILLA, SPEC]AL GOVERNMENT PLEADER FOR STATE TAX WRIT PETITION NO: 15632 OF 2025 Between: Yll-".!L D_rgital.l-,,.v,,r Systems private. Limited, rep py its Dirr;ctor. Mr. K.B.Baba, 401203. Ptot Nc {}5. Sri Raghavenara Nag'ar, "tuo'uraii - Hyo-eiao"o bb-o'-o+0, Telangana. .,.PETITlONER AND 1 2 ) Assistant ()c,rrrr rss ioner (sr), Tarnaka - r circre, Secunde rabad Division, Telangana. Deputy Conrnr ssroner (ST), Enforcement Wing, Nampaly, Hyderabad, Telangana. State of Jr:lirrc'ana. ren by its Secretary to Governme,nt (l.T) State Tax Departmen- S,i:'etariat, Hyderabad. 9 4 Union of lndia, rep. by its Secretary (Revenue)' North Block, New Delhi ...RESPONDENTS Petition under Article 226 of the constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ of lt/landamus or any other appropriate writ or order or direction by setting aside the impugned show cause notice dated 31.1 .2024 along with proceedings in Form GST DRC-01 vide Ref. No=2D360124044943G dated 31.1.2024 and order dated 3O.4.2024 along with proceedings in Form GST DRC- 07 vide Ref.No .2D36O424092550F dated 30.4.2024 issued by the 1st Respondent for the tax period April. 2018 to lvlarch,2019 without having any signatures as illegal, without jurisdiction and contrary to the provisions under the central Goods and service Tax Act, 2017 and the Telangana Goods and Services Tax Act, 2017, and void in absence of non-compliance of Rule 142(1A) of the central Goods and service Tax Rules, 2017 and Telangana Goods and services Tax Rules, 2017- 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 grant stay of all further proceedings pursuant to the impugned order'.dated 30 4 '2024 along with proceedings in Form GST DRC-07 vide Ref.No.2D.360424092550F dated 30.4.2024 issued by the l.tRespondent for the tax period April,201B to March, 2019 under the Central Goods and Service Tax Act, 2017 and the TelanganaGoodsandServicesTaxAct,20.lTpendingdisposaloftheWrit Petition as otherwise the Petitioner will be put to severe loss hardship' Counsel for the Pqtitioner: SRI K- P. AMARNATH REDDY Counsel for the Respondents No.1 to 3: SRI SWAROOP OORILLA, SPECIAL GOVERNMENT PLEADER FOR STATE TAX Counsel for the Respondent No.4: SRI GADI PRAVEEN KUMAR' - DEPUTY SOLICITOR GENERAL OF INDIA t0 WRIT PETITION NO: 15824 OF 2025 Between: M/s. Power Linl< Svr;,ems, 11118215, Shivalaya Road, Fathenagar, Balanagar, Medchal Malkajgrri 1'alangana - 500 018, represented by its l)rop-ieto-, Sri Bhaskara Chary VuppalojLr PETITIONER AND 1 Assistant ,: cmnr ssioner (ST), Fatehnagar Circle, Hyderabad Lural Division, Hyderabacl 2. The Brant:h Hyderabad llanager, lClCl Bank, Sanjeeva Fleddy N agar Branch, 3. The State of Telangana, represented by its Principal Secretary, Revenue Departmenl (C;orrmercial Taxes), Tetangana Secretarir:t, Hyderabad. .RI;iSPONDENTS Petition und,:r a rticle 226 of the Constitution of lndia f)rayi ig that in the circumstances staterj in the affidavit filed therewith, the Hi(rh ( )ourt may be pleased to issue er \A'.rt or Order or direction particularly one in tfre n;rture of Writ of Mandamus setti rg :rr; Ce the Show Cause Notice and impuqner I Assessment Order passed by the first respondent rn Form GST DRC 07, in Reference No.2D3604240955111€, dated 30.04.2024, thereby levir:d tax amounting to Rs.'16,45,728l-, ((lGS;.' amounting to Rs.8,22,8641 + SG{lT amounting to Rs.8,22,8641), fo'' the tax period 2018-19, that have been upl,radr,d in the GST portal without eithe' Jrllrsically nor digitally signed which is r:ontrary o the Rule 26 (3) of the CGST liu e: 2017, as illegal, arbitrary, ab initio vord, ccntrary to the provisions of CGSIT l\ci and Rules, 2017 and TGST Act anc Rules. .1017, contrary to the law laid dcr,vrr by the judicial p[onouncement of this l-lon'lrle Court and Hon'ble High Corrrls cf Delhi, Bombay and Andhra Pradesh and wilhout authority of law. lA NO: 1 OF 2025 Petition unrier Serction 151 CPC praying that in the c rcunrsta rces stated in the affidavit filed rr s:pport of the petition, the High Court may l,e pleased to suspend the operat o r of the impugned Garnishee NoticeiBank l\ttat hment issued l1 by the first respondent in Form GST DRC - 13, dated 18.03.2025, to the bankers of the petitioner firm i.e., the second respondent herein. lA NO: 2 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 grant stay of all further proceedings arising in pursuance of the impugned Assessment Order passed by the first respondent in Form GST DRC - 07, in Reference No.2D3604240955916, dated 30.04.2024, for the tax period 2018-1 9' Counsel for the Petitioner: SRI S. SURI BABU Counsel for the Respondents No.1 & 3: SRI SWAROOP OORILLA' SPECIAL GOVERNMENT PLEADER FOR STATE TAX Counsel for the Respondent No.2: - WRlT PETITION NO: 15847 OF 2025 Between: lvl/s. Power Link Systems, 11118215, Shivalaya Road, Fathenagar, Balanagar, Medchal Malkajgiri, T'elangana - 5OO O'18, repres6nted by its Proprietor, Sri Bhaskara Chary Vuppaloju. ...PETITIONER AND 1 2 J Assistant Commissioner (ST), Fatehnagar Circle, Hyderabad Rural Division, Hyderabad. The Branch Manager, lclCl Bank, Sanjeeva Reddy Nagar Branch, Hyderabad. The State of Telangana, represented by its Principal Department (Commercial Taxes), Telangana Secretariat Secretary, Revenue Hyderabad. ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to lssue a Writ or Order or direction particularly one in the nature of Writ of Mandamus setting aside the Show Cause Notice and impugned Assessment order passed by the first respondent in Form GST DRC - 07, in Reference No.2D3601250218988, dated 16.01.2025, thereby levied tax amounting to 1: Rs.61,554/-. (CGIST zrrrounting to Rs.30,777l- + SGST anrounting to Rs.30,777l-), for the tax period 2lc'7-'1 B, that have been uploaded in the GS l- portal without either physically nor digitally signed which is contrary to the Ru e 26 (3) of the GGST Rules 201'7 a:; illegal, arbitrary, ab initio void, conlrary to tlre provisions of CGST Act and Ftules. 2011 and TGST Act and Rules, 2017, cottary to the law laid down by thr: jucicial pronouncement of this Hon'ble court ar d Hon'ble High Courts of Delhi, Elcn-k,ay and Andhra Pradesh and without auil.oritr of law. lA NO: 1 OF 2021; Petition u'der Section 151 cpc praying that in the circums ances stated in the affidavit file,1 n r;:pport of the petition, the High court may be pleased to suspend the oprr:ratior of the impugned Garnishee Nolice / B(1nk Attachment issued by the firr;t rer;pondent in Form GST DRC - 13, dated 1g.03.2025, to the bankers of the peti:ic ner firm i.e., the second respondent herein. lA NO: 2 OF 202{; Petition und,:r llection 1 51 CPC praying that in the circrjmslances stated in the affidavit filed rn s L pport of the petition, the High court may. be pleased to stay of all further proc:eclirrgs arising in pursuance of the impulynec As:,,essment order passed by the f irr;l respondent in Form GST DRC - 07, in Reference No.2D36012502189t1i1 dated 16.01.2025, for the tax perio,J 2017.18. Counsel for the P€,titioner: SRI S. SURI BABU Counsel for the Re'spondents No.1 & 3: SRI SWAROOP OOR|LLl,, SPECIAL GOVERNMENT PLEADER FOR STA TE TAX Counsel for the Res oondent No.2: - WRIT PETITION NO:1 5886 0F 2025 Between: M/s. Seion Elecrrrcars private Limited,- Represented by sujat Bag hadia, Director Havins office ar []rot rlc 42. Sy. No 303 R;; R;Jdtrualai ieeoim:iir, rlvoEi"]"0, Telangana, 500055 AND ...PET|TIONER l3 1. Assistant Commissioner (ST), Jeedimetla ll, Hyderabad, Rural, Telangana 2. Commissioner of State Tax Telangana, Commercial Tax Building, Nampally' Hyderabad 3. State of Telangana, Rep. by its Principal Secretary (Revenue) CT' Department, Telangana, Secretariat Buildings, Hyderabad ...RESPONDENTS Petition under Article 226 of lhe constitution of lndia praying that in the circumstances stated in the affidavit filed therewith, the High court may be pleased to issue a writ, order or Direction more particularly, one, in the nature of writ of Mandamus setting aside and quashing the unsigned show cause notice issued u/s 73 dated 28.11.2024 and the unsigned attachment in Form No. DRC-o1 issued to the Petitioner for the tax period 2018-19 as void and non-est in law Set aside the unsigned assessment (audit) order dated 25.o2.2025 levying tax, penalty and interest as invalid and without legal effect, And pass 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 direct the respondents not to take any further steps consequent to passing of the assessment (audit) order dated 25.02.2025 levying tax, penalty, interest, pending disposal of the above writ petition. Counsel for the Petitioner: SRI P. SOMA SHEKAR REDDY Counsel for the Respondents: SRI SWAROOP OORILLA' SPECIAL GOVERNMENT PLEADER FOR STATE TAX Counsel for the Respondent No.2: -