Writ petition remitted for fresh consideration where limitation and penalty challenges remained unexamined beyond Section 174 validity issue.

The writ petition was not limited to the constitutional validity of Section 174 of the Kerala Goods and Services Tax Act; it also challenged the penalty orders on the ground that proceedings were initiated beyond the limitation under Section 67 of the Kerala Value Added Tax Act. As the earlier disposal addressed only the validity of Section 174 and did not examine the remaining grounds, those issues required fresh consideration. The writ appeal was allowed and the writ petition was remitted to the Single Judge for reconsideration of the other grounds, excluding the challenge to Section 174.

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Issues: Whether the writ petition required fresh consideration on grounds other than the challenge to the constitutional validity of Section 174 of the Kerala Goods and Services Tax Act, including the plea of limitation under Section 67 of the Kerala Value Added Tax Act.

Analysis: The challenge before the Court was not confined to the constitutional validity of Section 174 of the Kerala Goods and Services Tax Act. The penalty orders were also assailed on the ground that the proceedings were initiated beyond the limitation prescribed under Section 67 of the Kerala Value Added Tax Act. Since the earlier writ disposal had considered only the validity of Section 174 and had not examined the other grounds, the matter required reconsideration on those remaining issues.

Conclusion: The writ appeal was allowed and the writ petition was remitted for fresh consideration by the Single Judge on the issues other than the validity of Section 174 of the Kerala Goods and Services Tax Act.

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