2025 (1) TMI 590

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....mmed Anajwalla i/b Economic Laws Practice, Advocates. For the Respondent: Mr. Y.R. Mishra a/w Sangeeta Yadav, Advocates. P.C. 1. The above Writ Petition is filed by the Petitioner seeking a declaration that the activity of a holding company providing a corporate guarantee to its subsidiary is not in the nature of "supply" and/or "supply of service" taxable under Section 9 of the Central Goods....

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....ring on behalf of the Respondents submitted that since the Final Audit Report [of the audit conducted] has been issued, the office of the Assistant Commissioner (Circle-VI), CGST Audit-I Commissionerate Pune is not pursuing the matter arising out of the letter dated 1st February 2024 and which is impugned in the said Writ Petition. He submitted that since the Respondents are not pursuing the matte....

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....23. 4. Considering that this is an important issue, we grant time to the Respondents to file their affidavit-in-reply to the above Writ Petition in so far as it lays a challenge to the circular dated 27th October 2023 and also to the extent that the Petitioner seeks a declaration that the activity of a holding company providing a corporate guarantee to a subsidiary is not in the nature of "supply....