M/S. G.K. Granites LTD. vs. The Assistant Commissioner, Special Circle, State Goods & Service Tax

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WP(C)/10221/2018HC KeralaGSTCNR KLHC01041811201827 March 2018Bench: HONOURABLE MR. JUSTICE P.B.SURESH KUMAR6 pages

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Heard together (2 matters)

W.A NO. 428/2017
W.P(C) NO. 5253/2018

Read from the judgment's own cause title. This page is filed under one of them.

Cause title — parties, addresses and appearances
IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT: THE HONOURABLE MR. JUSTICE P.B.SURESH KUMAR TUESDAY, THE 27TH DAY OF MARCH 2018 / 6TH CHAITHRA, 1940 WP(C).No. 10221 of 2018 PETITIONER(S) M/S. G.K. GRANITES LTD. VELLAVOOR, CHENGANASSERY, REPRESENTED BY THE MANAGING DIRECTOR, SRI. GEORGE ANTONY RESIDENT OF KUREEKKAL HOUSE, KIZHAKKAMBALAM, KUNNATHATHUNAD, ERNAKULAM DISTRICT. BY ADV.SRI.N.JAMES KOSHY RESPONDENT(S): 1. THE ASSISTANT COMMISSIONER, SPECIAL CIRCLE, STATE GOODS & SERVICE TAX PERUMBAVOOR 683542 2. THE DEPUTY COMMISSIONER (APPEALS) V STATE GOODS AND SERVICES TAX DEPARTMENT, ERNAKULAM, KOCHI-682 015 3. THE DEPUTY COMMISSIONER COMMERCIAL TAXES, MATTANCHERRY, KOCHI 682 002 R BY SR.GOVERNMENT PLEADER, SRI.V.K.SHAMSUDHEEN THIS WRIT PETITION (CIVIL) HAVING COME UP FOR ADMISSION ON 27-03-2018, THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING: WP(C).No. 10221 of 2018 (C) APPENDIX PETITIONER(S)' EXHIBITS EXHIBIT P1 TRUE COPY OF THE MINING LEASE AGREEMENT 24-11-2016 EXT.p1(A) PROCEEDINGS OF THE DIRECTOR OF MINING AND GEOLOGY, THIRUVANANTHAPURAM DATED 27-08-2016. EXHIBIT P2 TRUE COPY OF THE REGISTRATION CERTIFICATE DATED 04-04-2017 ISSUED BY THE DIRECTOR OF MINING AND GEOLOGY DEPARTMENT, KERALA TO THE PETITIONER EXHIBIT P3 TRUE COPY OF THE CENTRAL SALES TAX REGISTRATION CERTIFICATE NO. 23148210 DATED 28-02-2004 ISSUED BY THE SALES TAX OFFICER, PERUMBAVOOR TO THE PETITIONER EXHIBIT P4 TRUE COPY OF THE OFFICE MEMORANDUM F.NO. 28011/03/2014-ST-II DATED 07-11-2017 ISSUED BY THE MINISTRY OF FINANCE, DEPARTMENT OF REVENUE, STATE TAX DIVISION, GOVERNMENT OF INDIA EXHIBIT P5 TRUE COPY OF THE CLARIFICATION LETTER DATED 19-10-2017 ISSUED BY THE JOINT COMMISSIONER OF STATE GOODS AND SERVICE TAX, THIRUVANANTHAPURAM TO INDIAN RARE EARTH LTD, CHAVARA. EXHIBIT P6 TRUE COPY OF THE JUDGMENT IN W.A NO. 428/2017 OF THE HON'BLE HIGH COURT OF KERALA, ERNAKULAM EXHIBIT P7 TRUE COPY OF THE ORDER NO. 32151370735/2017-18 DATED 09-01-2018 ISSUED BY THE 1ST RESPONDENT TO THE PETITIONER EXHIBIT P8 TRUE COPY OF THE APPEAL DATED 05-02-2018 FILED BEFORE THE 2ND RESPONDENT BY THE PETITIONER EXHIBIT P9 TRUE COPY OF THE PETITION FOR STAY DATED 05-02-2018 FILED ALONG WITH EXHIBIT P-8 APPEAL EXHIBIT P10 TRUE COPY OF THE JUDGMENT IN W.P(C) NO. 5253/2018 DATED 16-02-2018 OF THE HON'BLE HIGH COURT OF KERALA,ERNAKULAM. EXHIBIT P11 TRUE COPY OF THE ORDER DATED 28-02-2018 IN APPEAL KVATA NO. 441/18 OF THE 2ND RESPONDENT EXHIBIT P12 TRUE COPY OF CERTIFICATE NO. 32060741872/2017-18 DATED 28-11-2017 ISSUED BY THE INSPECTING ASSISTANT COMMISSIONER, IDUKKI AT KATTAPPANA. RESPONDENT'S EXHIBITS : NIL //TRUE COPY// SD/- P.A. TO JUDGE SKS P.B.SURESH KUMAR, J ================ W.P.(C) Nos. 10221 & 10222 of 2018 - - - - - - - - - - - - - - - - - - - - - - - - - - - Dated this the 27th day of March, 2018

JUDGMENT In exercise of the power under Section 7(4) of the Central Sales Tax Act (the Act), the asssessing authority of the petitioners has suo motu amended the certificate of registration of the petitioners under the Act and revoked the authorization granted to effect interstate purchase of fuel with effect from 01.07.2017. Ext.P7 in W.P.(C.) No.10221 of 2018 is the order issued to the petitioner therein in this connection. A similar order has been issued to the petitioner in W.P.(C.) No.10222 of 2018 also. The petitioners challenged the said orders in appeal before the second respondent. The said appeals stand dismissed on the ground that the appeals are not maintainable. The petitioners are aggrieved by the said

W.P.(C) Nos. 10221 & 10222 of 2018 -2- orders and hence these writ petitions.

2.

Heard the learned counsel for the petitioners as also the learned Government Pleader.

3.

As noted above, orders impugned in the appeals preferred by the petitioners are orders issued under Section 7(4) of the Act. In the light of the provision contained in Section 9(2) of the Act, the remedy of the petitioners against the orders issued under Section 7(4) of the Act, has to be determined with reference to the provisions contained in the Kerala Value Added Tax Act (VAT Act). The provision corresponding to Section 7(4) of the Act in the VAT Act is Section 16(10). The question to be examined, therefore, is whether an appeal lies under the VAT Act against an order issued under Section 16(10). It is seen that Section 55(1) of the VAT Act dealing with the right of appeal against orders issued under the said statute has been amended in terms of the provisions contained in the Finance Act, 2017. Section 55(1) of the VAT Act, as amended in terms of Finance Act,

W.P.(C) Nos. 10221 & 10222 of 2018 -3- 2017 without its provisos, reads thus: “(1) Any person aggrieved by any order issued or proceedings recorded other than those under sub-section (3), sub- section (8) or sub-section (9) of section 16 and sub-section (8) of section 19 passed by an authority empowered to do so under this Act not being an authority above the rank of an Assistant Commissioner may, within a period of thirty days from the date on which the order was served on him, appeal against such order, (i) to the Deputy Commissioner (Appeals), if the order was passed by the authority of the rank of an Assistant Commissioner; and (ii) to the Assistant Commissioner (Appeals), if the order was passed by an authority of the rank of a Commercial Tax Officer.” In the light of the aforesaid amended provision, the petitioners are entitled to prefer appeals challenging the orders issued under Section 7(4) of the Act. It is seen that the impugned orders have been rendered without taking note of the amendment introduced to Section 55(1) of the VAT Act in terms of the provisions contained in Finance Act, 2017. In the result, the writ petitions are allowed, the impugned orders are set aside and the second respondent is directed to pass fresh orders on the appeals preferred by the petitioners in accordance with law, after affording the W.P.(C) Nos. 10221 & 10222 of 2018 -4- petitioners an opportunity of hearing. This shall be done within one month from the date of receipt of a copy of this judgment. P.B.SURESH KUMAR JUDGE SKS

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