Facts of the Case
The petitioner, Globe Overseas Pvt. Ltd., filed a writ petition
challenging the adjudication order dated 24.08.2024 passed by the Sales Tax
Officer, Class II/Avato Ward 63, Zone-6, Delhi for Financial Year 2019-20,
pursuant to a show cause notice dated 19.05.2024. By the impugned order, a
demand of ₹12,30,763 was raised against the petitioner. The petitioner also
challenged Notification Nos. 9/2023 (Central Tax), 9/2023 (State Tax), 56/2023
(Central Tax), and 56/2023 (State Tax), which extended limitation periods for
issuance of notices and passing of orders under the GST regime. The challenge
to the notifications formed part of a larger batch of matters pending before
the Delhi High Court, with the lead matter being DJST Traders Private Limited
vs. Union of India, and the issue being simultaneously under consideration
before the Supreme Court.
Issues Involved
Whether the impugned GST adjudication order passed without granting a
personal hearing and without considering the petitioner’s reply violates
principles of natural justice, whether the challenge to the limitation
extension notifications under Section 168A of the CGST Act can be adjudicated
independently, and whether the matter ought to be remanded for fresh
consideration.
Petitioner’s Arguments
The petitioner contended that the show cause notice dated 19.05.2024 and
the reminder notice dated 13.07.2024 were uploaded on the ‘Additional Notices’
tab on the GST portal and did not come to the petitioner’s knowledge. It was
argued that the impugned order was passed ex parte without affording the
petitioner an opportunity to file a reply or to be heard, thereby violating the
principles of natural justice. The petitioner further challenged the validity
of the notifications extending limitation under Section 168A of the CGST Act.
Respondent’s Arguments
The respondents submitted that after 16.01.2024, changes were made to
the GST portal making the ‘Additional Notices’ tab visible, and therefore the
petitioner could not claim lack of knowledge of the notices. It was further
contended that the notifications were validly issued and that similar
challenges were pending before the Supreme Court.
Court Order / Findings
The Delhi High Court held that the petitioner’s contention regarding
non-visibility of notices on the GST portal was untenable in view of the
changes made after 16.01.2024. However, the Court observed that the impugned
order had admittedly been passed without a reply being filed by the petitioner
and without effective opportunity of hearing. Relying on its earlier decision
in Sugandha Enterprises vs. Commissioner, DGST, the Court held that in such
circumstances, the matter ought to be remanded to enable the petitioner to
contest the show cause notice on merits. The Court declined to adjudicate on
the validity of the impugned notifications, keeping the issue open and subject
to the outcome of proceedings pending before the Supreme Court and connected
matters before the Delhi High Court.
Important Clarification
The Court clarified that while the adjudication order was being set
aside on the ground of violation of principles of natural justice, the issue
concerning the validity of the notifications issued under Section 168A of the
CGST Act remained open. Any fresh order passed by the adjudicating authority
would be subject to the final outcome of the proceedings pending before the
Supreme Court in SLP No. 4240/2025 and related matters.
Final Outcome
The writ petition was disposed of by setting aside the impugned
adjudication order dated 24.08.2024, subject to payment of ₹10,000 as costs to
the Delhi High Court Bar Association. The petitioner was granted time till
31.01.2026 to file a reply to the show cause notice, and the adjudicating
authority was directed to grant a personal hearing and pass a fresh order in
accordance with law, subject to the final decision of the Supreme Court on the
validity of the impugned notifications.
Source
Link- https://delhihighcourt.nic.in/app/showFileJudgment/75424122025CW196572025_180015.pdf
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