GST demand based on duplicated turnover across same-PAN registrations was quashed as unsustainable.

A GST show cause notice and consequential demand were held unsustainable where the alleged turnover mismatch arose from two registrations linked to the same PAN and the relevant turnover had already been reported in returns filed under the other registration. The court accepted that the demand was based on duplicated figures and noted that the respondents could not dispute this factual foundation. As the demand machinery was invoked on a duplicated turnover basis, the notice and demand were quashed and the impugned GST proceedings were set aside.

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Issues: Whether the show cause notice and demand under the GST regime could be sustained when the alleged turnover difference arose from two registrations linked to the same PAN and the corresponding returns had already been filed in relation to the other registration.

Analysis: The petitioner showed that the turnover figures forming the basis of the demand were already reflected in the returns of another firm under the same PAN. The respondents were unable to dispute that the impugned notice and demand were founded on this duplication. In that situation, the basis for invoking the demand machinery was not sustainable.

Conclusion: The show cause notice and the consequential demand could not be sustained and were quashed.

Final Conclusion: The writ petition succeeded and the impugned GST proceedings were set aside.

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