Tax Appeals Get Lifeline: Limitation and Pre-Deposit Hurdles Removed for Taxpayers Seeking Fair Hearing by July 15, 2025

HC resolved tax duplication issue for taxpayer, directing that appeals filed by 15th July 2025 will be accepted without dismissal due to limitation or pre-deposit concerns. Court limited pre-deposit to first order's total amount and ensured both tax orders would be adjudicated on merits, providing relief against procedural barriers.

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The Delhi High Court, in a petition under Articles 226 & 227 of the Constitution of India, addressed duplication of a tax amount of Rs. 17,10,034/- imposed twice on M/s Caretech Systems in two separate Orders-in-Original dated 28th January 2025 and 1st February 2025 by CGST authorities. The Court observed that the same amount was duplicated in both orders. It held that the Petitioner may file two appeals under Section 107 of the Central Goods and Service Tax Act, 2017, but the pre-deposit requirement shall be limited to the total amount mentioned in the first order (Rs. 81,41,737/-), covering both sums, and no pre-deposit is required for the second order. The Court directed that the appeals filed by 15th July 2025 "shall not be dismissed on the ground of limitation or lack of pre-deposit and shall be adjudicated on merits." The order was passed on the unique facts of the case and disposed of the petition accordingly.

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