BharatTaxGST

M/S. Cyher Homes vs. The Joint Commissioner Of State Tax

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WP/13725/2023HC TelanganaGSTCNR HBHC01025182202320 June 2023Bench: N.TUKARAMJI,UJJAL BHUYAN14 pages
AI SummaryRemanded

Facts

The petitioners approached the High Court challenging orders issued under Section 73 of the CGST Act. They argued that the orders were passed without proper examination of their accounts, specifically regarding the reversal of input tax credit.

Held

The Court set aside the impugned orders and remanded the matters back to the assessing authority for fresh consideration. The assessing authority was directed to provide the petitioners with an adequate opportunity of hearing and to pass fresh orders within six weeks.

Key Issues

The primary issues were the lack of an appellate authority to hear appeals and the alleged non-examination of the petitioners' books of accounts by the assessing authority.

Sections Cited

Section 73, Rule 109A

AI-generated summary — verify with the full judgment below

Cause title — parties, addresses and appearances
,| [ 3311 ] HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD (Special Original Jurisdiction) TUESDAY, THE TWENTIETH DAY OF JUNE TWO THOUSAND AND TWENTY THREE PRESENT THE HONOURABLE THE CHIEF JUSTICE UJJAL BHUYAN AND THE HONOURABLE SRI JUSTICE N.TUKARAMJI WRIT PETITION NOS: 13723 13724 13725 13726 13728 13731 13732 13738 AND 13742 0F 2023 W.P.NO: 13723 OF 2023 Between: M/s. Western Constructions, Having its office at Western Pearl, 8th Floor, B-D, SY. No. 13 P, Hi-Tech City Main Road, Madhapur, Hyderabad Telangana 500 084 represented by its Partner, Mr. Siva Rama Raju Gottumukkala, S/o. Sri. Q. Satyanarayana Raju, aged about 61 years, FJo. A-717, Westem Plaza, Sy. No. 14, 20, 21 , 22, 23, Dargah Hussain Shahwali, OU Colony, Shaikpet, Golconda, Hyderabad 500008. ...PETITIONER AND The Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hyderabad 50000'1 . State of Telangana, Through Principal Secretary to Government, Revenue Department (Commercial Tax), Hyderabad, Telangana. ...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 particularly one in the nature of a WRIT OF MANDAMUS declaring the impugned order vide DRC-07 dated 01.03.2023 issued by the 1st Respondent demanding Rs. 3,36,40,698/- towards tax along with applicable interest and Notice in DRC-01 vide Ref. No. 2D361 12101 1001 K dated 13.11.2O2'l as being void, illegal, arbitrary, violative of Articles 265 of the Constitution of lndia, violative of principles of natural justice, and without authority of law and consequently set aside the same. 1 2 lA NO: 1 OF 2023 Petition Lrnder S3ction 15'1 CPC praying that in tle cir,)L Tstances stated in the affidavit filed in s r[,port of the petition, the High Co]rt rnz y be pleased to stay all further pror;eedir g:; pursuant to the lmpugned C)rder virje Reference No- 2D360323001076'/ leted 01 .03.2023 and Notice ir DRO-()'1 vide Ref. No. 2D361121011001K . ated 13 1 1 2021 passed by Respo rdent No.1 . W.P.NO: 13724Ot 2t23 Between: M/s. Cyber llo ners, Having its office at Cyberhomes, Plct No. 55, 4th Floor, Sathsurya Crn plex, Road No. 36 extended, Jubi|:e Hills loerd, Kavuri Hills, Above Thirupa hi Electronics, Hyderabad, Telangana - 5:)00:13 represented by its Managinl Fartner Sri Venu Vinod Vedra, S/o R.D. B'roolral, aged about 63 years, R/o. I 'lct No. 1056, Road No. 52, Jubilee hills, Ily,lerilbad - 500033 ..PETITIONER . AND 1. The Joint Comr rissioner of State Tax, Hyderabad Fural Division, 4th Floor, East Wing, Gag ar Vihar Complex, Opp. Gandhi Bh,rvan, \r, mpally, Hyderabad - 50 )001. 2. State of Telarrg rn,a, Through Principal Secretary to Goverrnrent Revenue Department (Cc mmercial Tax), Hyderabad, Telangzrna. ..RT:SPONDENTS Petition underr \rticle 226 of lhe Constitution of lndia prayirg that in the circumstances statr:cl irr the affidavit filed therewith, the Hig r Oourt may be pleased to issue a Wrr , r)rder Dr direction particularly on 3 in the rature of a writ of Mandamus declaring ho lmpugned order vide DRC-O7 dateC '1 10:2.2023 issued by the 1st Resoondt nt demanding Rs. 4,99,85,802/- towirrdr; tzrx along with applicable interest an I ltlotice in DRC-O1 vide ref.No. )\D3611'.,10t)5438T dated 12.11.2021 as reingl void, illegal, arbitrary, violative of ,A.ti,;le: 265 of the Constitution of lndia, , olative of principles of natural lust ce, and without authority of law and conseque,nt y set aside the same. ) lA NO: 1 OF 2023 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 stay all further proceedings pursuant to the lmpugned Order vide Reference No. 2D36O223O31655M dated 14.02.2023 and Notice in DRC-01 vide Ref.No. 2D361121005438T dated 12.11.2021 passed by Respondent No.1. W.P.NO: 13725OF 2023 Between: M/s. Cyber Homes, Having its office at Cyberhomes, Plot No. 55, 4th Floor, Sathsurya Complex. Road No.36 extended, Jubilee Hills Road, Kavuri Hills, Above Thirupathi Electronics, Hyderabad, Telangana - 500033 represented by its Managing Partner Sri Venu Vinod Vedra, S/o. R.D. Bhoopal, aged about 63 years, Rl/o. Plot No. 1056, Road No. 52, Jubilee hills. Hyderabad - 500033 ...PETITIONER AND 1. ?he Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hyderabad - 500001 2. State of Telangana, Through Principal Secretary to Government, Revenue Department (Commercial Tax), Hyderabad, Telangana. ...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 particularly one in the nature of a writ of mandamus declaring the impugned order vide DRC-07 dated 1410212023 issued by the 1st Respondent demanding Rs. 8,02,98,662/- towards tax along with applicable interest and Notice in DRC-O1 vide Ref. No.2D36O222018517N dated '1910212022 as being void, illegal, arbitrary, violative of Articles 265 of the Constitution of lndia, violative of principles of natural justice, and without authority of law and consequently set aside the same. lA NO: 1 OF 2023 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 stay .-- rr all further procer:cirgs pursuant to the lmpugned ()rder v de Reference No 2D360223031'727 J daled 1410212023 and Notice in DIt(.:-0'1 vide Ref.No 2D3602220181117N lated 1910212022 passed by Respc,nden l.o.1. W.P.NO: 13726 OF 1023 Between: M/s. Aqua {l race Developers Private Limited, Har ir g i:s office at 1 - 123lMHlg01, { th Floor, My Home Hub, 3rd Block, Madlarur, Serlingampally, Ranga RedrJy Telangana -500081, represented by its Direclor Sri J. Vinod, S/o. Sri Rarn, srvar Rao Jupally, aged about 4'1 years R/:. Plot No. 53, Nandagiri Hilk Oo-op Housing Society, Jubilee llills, llyCerabad - 500033, Telangana Sta e ...PETITIONER AND 1 . The Joinl Ccrnr rissioner of State Tax, Hyderabad Rural [)r', isic n, 4th Floor, East Wing, Oa yan Vihar Complex, Opp. Gandhi Btravan, Nlamlrally, Hyderabad - 5( 0()0'l . 2. The Commis;sir n'lr of State Taxes, C.T. Complex, I'Jamp;rll'r, Hyderabad - 500004 3. State of 1'elang ana, Through Principal Secretary to Gove'n nerrt, Revenue Department iC >nrmercial Tax), Hyderabad, Telangana. .RESPONDENTS Petition under A(icle 226 of the Constitution of lndia Iraying that in the circumstances sta:e< in the affidavit filed therewith, the t1i,.rh Court may be pleased to issue a \Ar it, Order or direction particularly orre in t re: nature of a WRIT OF I\4ANDAIVUS der la.ing the impugned order vide [)RC-O7 dal=d 15.O2.2O23 issued by the ' st R, ,spondent demanding Rs. 29,83,2 4,08C/-lcw;rrds tax along with applicable intere st and Notice in DRC-o1 vide Ref Nc. 2D301'12'10053404 dated 12.'1 1.2Oi'1 its, bt:ing void, illegal, arbitrary, violalive ol l)rticles 265 of the Constitution of lndra, /ic,lative of principles of natural justice, an,.t withoul authority of law and consequef ly set aside the same. lA NO: 1 OF 2023 Petition under I ieltion 151 CPC praying that in thl circun stances stated in the affidavit filed in st l[,ort of the petition. the High Coul mery tre pleased to stay all further proceedinr s pursuant to the lmpugned Order vrdr: Fleference No. 1 2D3602230325002 dated 15.O2.2023 and Notice in DRC-01 vide Ref.No 2D361121OO5340A dated 12.11.2021 passed by Respondent No.1. w.P.NO: 13728 OF 2023 Between: M/s. Western Constructions, Having its office at Western Pearl, 8th Floor, 8-D, SY. No.'13 P, Hi-Tech City Main Road, Madhapur, Hyderabad Telangana - 500 084 represented by its Partner, Mr. Siva Rama Raju Gottumukkala, S/o. Sri. G. SatVanarayana Raju, aged about 61 years, No. A-717, Western Plaza, Sy. No. 14, 20, i1, 22, 23, Dargah Hussain Shahwali, OU Colony, Shaikpet, Gblconda, Hyderabad - 500008. ...PETITIONER AND 1 . The Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hvderabad - 50000'1 . 2. Siate of Telangana, Through Principal Secretary to Government, Revenue pepartment (Commercial Tax), Hyderabad, Telangana. .) ...RESPONDENTS Petition under Article 226 ol 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 particularly one in the nature of a wRlT OF MANDAMUS declaring the impugned order vide DRC- 07 dated 0110312023 issued by the 1st Respondent demanding Rs. 3'96,04,787l- towards tax along with applicable interest and Notice in DRC- 01 vide Ref.No. 2D361121O10962V dated 12t1112021 as being void, illegal, arbitrary, violative of Articles 265 of the Constitution of lndia, violative of principles of natural justice, and without authority of law and consequently set aside the same. lA NO: 1 OF 2023 Petition under Section '1 51 CPC praying that in the circumstances stated in the affidavit filed in support of the petition, the High court may be pleased to stay all further proceedings pursuant to the lmpugned Order vide Reference No. ZD36O3230O1O59U dated O1lO3l2O23 and Notice in DRC- 01 vide Ref. No. 2D36112101O962V dated 1211112021 passed by Respondent No.1. / b W.P.NO: 13731 OF i023 Between: M/s. Western ()onstructions, Having its office at W3stern F'ear, Bth Floor, 8-D, SY. No. 1 3 F. Fi-Tech City Main Road, Madhap rr, HyCt, rabad Telangana - 500 084 repre;ented by its Partner, Mr. Siva Ranra Ralu Goltumukkala, S/o. Sri. G. Sirtyanr r:,yana Raju, aged about 61 years, No. l:;17, Western Plaza, Sy. No, 't4, 2a 1'.1 , 22, 23, Dargah Hussain Shahwali t)t.l Q1;l6ny, Shaikpet, Golcond;:. Fy,: :rabad - 500008. ..PETITIONER AND 'l . The Joint Cc,m nissioner of State Tax, Hyderabad Rural [)i',ision, 4th Floor, East Wing, Ga tar Vihar Complex, Opp. Gandhi Bl'ravan, N ampally, Hyderabad - 5( 0001. 2. State of 1-elang ana, Through Principal Secretary to Gove'nrnerrt, Revenue Department iC rnrmercial Tax), Hyderabad, Telangana. ..RESPONDENTS Petition Lrnder A(icle 226 o'f the Constitution of lndia 1:raying that in the circumstances sta.er in the affidavit filed therewith, the Hi,.rh 3ourt may be : pleased to issuer a rrV it Order or direction particularly ore in tlre nalure of a writ of mandamus declaring the impugned order vide DRC-07 date<l .)'1 .C 3.2023 issued by the 1st Respond-lrt demanding Rs. 3,73,72,2361 towe r(is tax along with applicable interest an I Notice in DRC-O1 vide Ref. No. ZD36 1121(r10980X dated 13.11.2021 as beinl vord, illegal, arbitrary, violative of lrr:icles 265 of the Constitutron of lrdii:, ,ic,lative of principles of natural justice, an,:, without authority of law and consequeI ly set aside the same. lA NO: 1 OF 2023 Petition under iiertion '151 CPC praying that in th-- cirr;r rn' sta nces stated in the affidavit filed in s, rt'ort of the petition, the High Coul ma) tre pleased to stay all further proceedinr s pursuant to the lmpugned Order v dr: Fleference No. 2D3603230010750 ,::t,:d 01 .03.2023 and Notice in DRO-:)1 vide Ref.No. 2D361121010980X d; ted 13.11.2021 passed by Respon,lent N o 1. W.P.NO: 137320F 2023 Between: l\I/s. Westem Constructions, Having its office at Western Pearl, 8th Floor, 8- D, SY. No. 13 P, Hi- Tech City Main Road, ltzladhapur, Hyderabad Telangana - 500 084 represented by its Partner, Mr. Siva Rama Raju Gottumukkala, S/o. Sri. G. Satyanarayana Raju, aged about 61 years, Rl/o. A- 717, Westem Plaza, Sy. No. 14, 20,21 ,22,23, Dargah Hussain Shahwali, OU Colony, Shaikpet, Golconda, Hyderabad - 500008. ...PETITIONER AND 'l . The Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hyderabad - 500001. 2. State of Telangana, Through Principal Secretary to Government, Revenue Department (Commercial Tax), Hyderabad, Telangana. ...RESPONDENTS Petition under Article 226 of the Constitution of lndia praying that in the circumptances stated in the affidavit filed therewith, the High Court may be ) pleased to issue a Writ, order or direction particularly one in the nature of a writ of mandamus declaring the impugned order vide DRC- 07 dated 01. 03. 2023 issued by the 1st Respondent demanding Rs. 2,48,65,074/- towards tax along with applicable interest and Notice in DRC- 01 vide Ref. No. 2D360222018569E dated 19. 02. 2022 as being void, illegal, arbitrary, violative of Articles 265 of the Constitution of lndia, violative of principles of natural justice, and without authority of law and consequently set aside the same. lA NO: 1 OF 2023 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 stay all further proceedings ptrsuant to the lmpugned Order vide Reference No. 2D3603230010817 dated 01. 03. 2023 and Notice in DRC- 01 vide Ref. No. 2O360222018569E dated 19. 02.2022 passed by Respondent No. 1. .47 / IL) / W.P.NO: 13738 OF : 023 Between: IVI/s. Cyber H< mes, Having its office at Cyberhornes, F lc: No. 55, 4th Floor, Sathsurya Oor rp,lex, Road No. 36 extended, Jubilee Hi ls Road, Kavuri Hills, Above Thirup: thi Eleclronics, Hyderabad, Telanllana - l:00()33 represented by its [\rlanal;ir J lrartner Sri Venu Vinod Vedra, S/o. R.D Elhoopal, aged about 63 years, Rro Dlct No. 1056, Road No. 52, Jubilee, hills, H',delabad - 500033 ...PETITIONER AND 'l . The Joinr Conr rissioner of State Tax, Hyderabad lRural l)i,,isic,n, 4th Floor, East Wing, (ia yan Vihar Complex, Opp. Gandhi Blravan, ltJam:ally, Hyderabad - 5r )01101. 2. State of -[elan1 ana, Through Principal Secretary tc Goverr.nerrt, Revenue Department (C rnrmercial Tax), Hyderabad, Telangana. ..,RESPONDENTS Petition under Article 226 of the Constitution o1 lndie ;:,raying that in the circumstances stater n the affidavit filed therewith, the llirlh Court may be please( to issue a W it, Order or direction particularly orre in t rer nature of a writ of mandamus declarinlr tl e impugned order vide DRC-07 dalerl '14.02.2023 issued by the 1st Responc -.rrt demanding Rs. 9,79,99,098/. towirrr. s 1ax along with applicable interest ar d Notice in DRC-O1 vide Ref.No. .2D36'1:11005526W dated 12.11.2021 as beinr void, illegal, arbitrary, violalive of r\rlicles 265 of the Constitution of lndir, /iolative of principles of natural .justice, :n:l wthout authority of law and consequer lly set aside the same. lA NO: 1 OF 2023 Petition und€rr : ;ection 15'1 CPC praying that in the c ircrr r,rsta nces stated in the affidavit filed in sL pport of the petition, the High Cou( mal l:e pleased to stay all further proceedinr s pursuant to the lmpugned Order vid,: Fleference No. 2D36O223O317C2V < aled 14.02.2023 and Notice ir DR()-r)1 vide Ref.No. 2D361 121005526!\' d ltt:d 12.11.2021 passed by Respondent,rJr..1. -.--7 W.P.NO: 13742OF 2023 Between: Mis. Cyber Homes, Having its office at Cyberhomes, Plot No.55,4th Floor, Sathsurya Complex, Road No.36 extended, Jubilee Hills Road, Kavuri Hills, Above Thirupathi Electronics, Hyderabad, Telangana - 500033 represented by its Managing Partner Sri Venu Vinod Vedra, S/o. R.D. Bhoopal, aged about 63 years, Fl/o. Plot No. 1056, Road No. 52, Jubilee hills, Hyderabad - 500033 ...PETITIONER AND 1. The Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hyderabad -500001. 2. State of Telangana, Through Principal Secretary to Government, Revenue Department (Commercial Tax), Hyderabad, Telangana. ...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, Order or direction particularly one in the nature of a writ of mandamus declaring the impugned order vide DRC- 07 dated 1410212O23 issued by the 'l st Respondent demanding Rs. 5,74,05,'1441 towards tax along with applicable interest and Notice in DRC-01 vide Ref.No. 2D361121O05486S dated 1211112021 as being void, illegal, arbitrary, violative of Articles 265 of the Constitution of lndia, violative of principles of natural justice, and without authority of law and consequently set aside the same. lA NO: 1 OF 2023 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 stay all further proceedings pursuant to the lmpugned Order vide Reference No. 2D36O223031681R dated 1410212023 and Notice in DRC- 01 vide Ref.No. 2D361121005486S dated 1211112021 passed by Respondent No.1. Counsel for the Petitioner ln All: SRI S.RAVI, M/s. R.S. ASSOCIATES Counset for the Respondents ln All: SRI L.VENKATESWAR RAO, SC FOR COMMERCIAL TAX DEPT

The Court made the following: COMMON ORDER

r).'titicnorri .tn(l Mr. L.Vcnkateswar Rao. leeun,:ri Standrng :li'r,r' I Mr. S.Ravi. Ii:arned Senior Co: rsel lor the Oor-rnsel o' Commcrcial Tax Departmr:rrt for the rcsporr dr l S (l| 1t6.06.2o2-it, the follorving ordcr c,amc to be aIIE H@U{.I4U;- E lItn'AN AND :HE HON'BLE SRI JUSTICE N. TI-'KARI JlI J I l{rit pp! rtigs&s. 13723. 13724. 13 7it0, r-3T28 3732 13738 and 13742 of 12023 CQI4IVIqN !,B!EE: tper th(! t k,t'bte tlre clnef rustice rrt r:ttuut.t.) passe< t lllrall(inp(' maclt' in these writ pet liorls is to the , rrlr r.; ;.,.tstcrl l-rr rcslrondcnt No. I unde: Scct ,r 7:\ o1' t lrc r'r rr ral (-ioods :rrri Sen,lccs lax Acr . 2O 1 / (briefl1, 'r lrr' (l( jSl- ,\ct' l-rereinafter). \r tlrc outset, a query lvas put to learrLt rl lierrior (l,rr.rl,.; I Io- thc petitioncrs as to why p'rLiti.;ner s have r-ot 1ri'frrr,:d alrpeals against thc aloresrrid orlr.s rrnd ins(r:rrr l ar'e a1.lproi:c:hed the writ court. ,r:arncd Senior (lounscl lbl the yretrtr,rrrc-s lras clr.rr,,r' Ll c ittt(ntiorr oI t]re Court to Rul(' l09A cf thc I I t 3731

2 Central Goods ald Services Tax Rules, 20 I7 (briefly 'the CGST Rules' hereinafter) and submits that arl appeal against any decision or order passed by the Additiona.l Commissioner or Joint Commissioner would lie before the Commissioner (Appeals); however, there is no Comrnissioner (Appeals) to hear the appeals of the petitioners. On merit, learned Senior Counsel for the petitioners submits tJ.at respondent No.1 had passed the impugned orders without examining the books of accounts of the petitioners, parLicularly on the point of reversal of input tax credit. Mr. L.Venkateswar Rao, learned Stalding Counsel for Commercia,l Tax Department representing the respondents to obtain instructions both on the availability of the appellate authority and also on the point as to whether the matters can be remanded back to the assessing authority on the short point of non- examination of the books of accounts of the petitioners. On request of learned Standing Counsel for the respondents, list these matters on 20.06.2023 under tl'e same caption.

3.

Mr. L.Venkateswar Rao, learned Standing Counsel submits on instruction that insofar availability of appellate authority is concerned, the clarihcation sought for by him I is still before the Government. However, it is evident thEt

no appelii: t1r authority has been constitutecl tr. dt:al u,ith a situatiorL Lke this. On the other hand, orr the pornt of remand, t e fairly submits that the a ssesr;i..rg authority u,oulci rr:-: xirminc the books of accounts of t h : petitioners and tl'rerez fter pass appropriate orders in ac:r;rdzrnce with I lau' responde r: No.I tbr considering the sarn<: afresh and 1. '['hat being the positior-r, we set aside -LLe impugned orders p,as se d by respondent No. 1 under Sectirrn 73 of the Centrrrl (lr orls and Services Tax Act, 2l)17 it ea,rh of the rvrit pt:titil nii ancl remand the matters bac.k t I the file of therearl'ter o pass appropriate orders irr accordance vvith Iau'. \eer- lrrss to sa] . respondent No.I shall provide 5. r\ll t.1-, ' 'r,rit petil-ions are accordingh' all,t,r,::d an adequ,rte r pl-'ortunitl' of hearing to the petir.iorrers and therealte: rhall pass the necessary ordors. Lr:t 1.he fresh orders on ; ernand be passed within a period uf six weeks from tlre dz tt, of receipt of a copy of this c rder.

r 4 To Miscellaneous applications pending, if any, shall stald closed. However, there shall be no order as to costs. . P.Ch. NAGABHUSHAMBA ASSISTANT REGIST //// SECTI OFFICER

1.

The Joint Commissioner of State Tax, Hyderabad Rural Division, 4th Floor, East Wing, Gagan Vihar Complex, Opp. Gandhi Bhavan, Nampally, Hyderabad 500001. 2. The Principal Secretary to Government, Revenue Department (Commercial Tax), Hyderabad, Telangana.

3.

One CC to M/s. R.S. ASSOCIATES, Advocate [OPUC]

4.

One CC to SRI L.VENKATESWAR RAO, SC FOR COMMERCIAL TAX DEPT IoPUCI

5.

Two CD Copies PSK GJP

HIGH COURT DATED:20106t2023 -1 .'\r\ \I^f€ v o 1 i l[\- MI _r l ' .-.' ,,, .-r reti-"4/ '-*- -- - -r- / COMMON OF DER WP. N os. 1 37 2 3, 1 37 24,1 37 25,1 37 26,1 37 2tl, 1 37 31, 13732,13738 ,\ND 13742 ot 2023 ALLOWING THE WRIT PETITIONS WITHOUT C )STS. )' (. R,I 4 t' lr-. --{l IAD

Reproduced from the public record of the Telangana High Court. Verify against the court's own copy before relying on it. Income tax judgments are on bharattax.net.