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2023 (12) TMI 70
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.... 15.09.2023 (hereafter 'impugned SCN'), raising several objections. 2. The petitioner submits that the impugned SCN is ex facie erroneous as it seeks to fasten a liability for the period when the petitioner was not active. 3. He submits that the Directors of the petitioner were in detention, and therefore, no business was carried out. 4. He submits that the impugned SCN is, inter alia, based on the premise that the petitioner is involved in providing service of online gaming. However, the petitioner does not have any wherewithal to provide any such services, and therefore, the assumption is ex facie incorrect. 5. He further submits that although the impugned SCN is issued by the Additional Director, Directorate General of GST In....
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....reads as under: "7.1 In respect of show cause notices issued by officers of DGGI, there may be cases where the principal place of business of noticees fall under the jurisdiction of multiple Central Tax Commissionerates or where multiple show cause notices are issued on the same issue to different noticees, including the persons having the same PAN but different GSTINs, having principal place of business falling under jurisdiction of multiple Central Tax Commissionerates. For the purpose of adjudication of such show cause notices, Additional/Joint Commissioners of Central Tax of specified Commissionerates have been empowered with All India jurisdiction vide Notification No. 02/2022-Central Tax dated 11th March, 2022. Such show caus....
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.... been issued and the maximum demand is proposed to be raised under the notice issued to Belz Tech Private Limited. Therefore, the Additional / Joint Commissioner of Central Tax, Thane would have jurisdiction to adjudicate the said notice. 11. In view of the statement made by Mr. Singla (on instruction of Mr. Neeraj Aggarwal, SIO, DGGI, DZU, who is present in Court) that multiple notices have been issued and the highest demand is covered under notice issued to Belz Tech Private Limited, which is registered in Thane, paragraph 7.1 of the Circular dated 09.02.2018 amended by the Circular dated 12.03.2022, as set out above, would clearly be applicable. 12. The petitioner's contention that the Additional / Joint Commissioner of Central Tax....