Ms International Engineer vs. State Of Punjab And Others
Facts
The petitioner, M/s International Engineers, challenged three adjudication orders dated 08.10.2022, passed under Section 73 of the Central Goods and Services Tax Act, 2017. These orders pertained to the financial years 2017-18, 2018-19, and 2019-20. The core of the petitioner's grievance was that they were not afforded an opportunity of a personal hearing before these orders were passed by the respondent authorities. The judgment does not specify the amount in dispute.
Held
The Court held that the three adjudication orders, all dated 08.10.2022, passed under Section 73 of the Central Goods and Services Tax Act, 2017, for the financial years 2017-18, 2018-19, and 2019-20, were indeed violative of the principles of natural justice. This violation stemmed from the fact that no opportunity for a personal hearing was granted to the petitioner. The Court further noted that this decision was in conflict with the law previously laid down by the same Court in CWP-33977-2025 – Kemexel Ecommerce Pvt. Ltd. vs. State of Punjab and others. Consequently, the impugned adjudication orders were set aside. However, the Court granted liberty to the respondents to proceed afresh against the petitioner in accordance with the law. The petition was allowed in these terms.
Key Issues
1. Whether the adjudication orders dated 08.10.2022, passed under Section 73 of the Central Goods and Services Tax Act, 2017, for the financial years 2017-18, 2018-19, and 2019-20, are violative of the principles of natural justice due to the denial of a personal hearing to the petitioner? Petitioner's Contention: The petitioner argued that the adjudication orders were passed without providing them with an opportunity for a personal hearing, which is a fundamental aspect of natural justice. They relied on the principles of natural justice and the judgment of this Court in CWP-33977-2025 – Kemexel Ecommerce Pvt. Ltd. vs. State of Punjab and others. Revenue's Contention: The judgment records no specific arguments made by the respondents (State of Punjab and another).
Sections Cited
Section 73
AI-generated summary — verify with the full judgment below
CWP-13600-2026 -1- IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH Sr. No.167 CWP-13600-2026 Date of decision: 04.05.2026 M/s International Engineers ....Petitioner Versus State of Punjab and another ....Respondents CORAM: HON'BLE MR. JUSTICE DEEPAK SIBAL HON'BLE MS. JUSTICE LAPITA BANERJI Present: Proxy counsel for Mr. J.S. Bedi, Advocate for the petitioner. Mr. Saurabh Kapoor, Addl. A.G., Punjab. * * * DEEPAK SIBAL, J. (Oral)
It is not disputed that at the time of passing the three adjudication orders, all dated 08.10.2022, under Section 73 of the Central Goods and Services Tax Act, 2017, pertaining to the financial years 2017-18, 2018-19 and 2019-20, no opportunity of personal hearing was afforded to the petitioner.
In the light of the above, not only are the impugned adjudication orders violative of the principles of natural justice but also in conflict with the law laid down by this Court through judgment dated 24.03.2026 passed in CWP-33977-2025 – responde
The judgment continues below.
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