TaxTMI 
TaxTMI 
2025 (8) TMI 1389
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....r alia, assailing the following impugned Orders-in-Original (hereinafter, collectively 'impugned orders'): (i) Order No. 90/ADJ-DGGI/DN/2024-25 dated 28thJanuary, 2025. (ii) Order No. 162/ADC/D.N./BHAVAN MEENA/2024-25 dated 01stFebruary, 2025. (iii) Order No. 57/ADC/D.N./SHAUKAT ALI NURVI/2024-25 dated 21stJanuary, 2025. (iv) Order No. 58/ADC/D.N./SHAUKAT ALI NURVI/2024-25 dated 21st January 2025. (v) Order No. 99/ADC/D.N./SHAUKAT ALI NURVI/ 2024-25 dated 29thJanuary, 2025. (vi) Order No. 158/ADC/D.N./BHAVAN MEENA/2024-25 dated 31stJanuary, 2025. 3. The above impugned orders relate to various Financial Years, being, 2017-2018, 2018-2019 and 2020-2021. These orders have been passed und....
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....ether in such matters multiple orders can be challenged in the same writ petition, especially after the period of limitation has already elapsed. 10. Secondly, in terms of the circular dated 6th July, 2022, the question that would arise is whether the Petitioner's stand is that it had engaged in actual supply of goods or services or whether there was no actual supply of goods or services. 11. The Court has put a query to ld. Counsel for the Petitioner as to whether, in the writ petition, there is a stand taken by the Petitioner on this aspect. 12. Mr. Jain seeks time to answer this query by the Court. The answer to the said query would be crucial in such a case where the application of the circular dated 6th July,....
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....pliers for same tax periods ? 1. DGGI/GZU/Gr.B/Inv/87/2018-19/ Part-IIIA/I, Un-dated Issued by DGGI, Gurugram 90/ADJ-DGGI/DN/ 2024-25 dated 28.01.25 2017-18, 2018-19, 2019-20 Tax 7,95,42,282/- (interest and penalty also demanded) Yes, in r/o 10 suppliers: • KM Enterprises, Radhey Enterprises(07EBPPK8485K1ZO), • Fusion Impex • Balaji Enterprises • Ambey Traders • P.S. Traders, • Radhey Enterprises(07BWTPG2717A2ZP), • Shree Raghupati Enterprises • Blue Pearl Enterprises • Garg Trading Co 2. No. 53/2025-26 dated 23.07.24 Issued by Sh. Manish Kumar Jha ADC, CGST Delhi North 162/ADC/D.N/Bhavan Meen....
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.... Delhi North 158/ADC/D.N./Bhavan Meena/ 2024-25 dated 31.1.2025 2017-18, 2018-19, 2019-20 2020-21, 2021-22 Tax Rs. 39,87,322/- (interest and penalty also demanded) Yes, in r/o 1 supplier, namely • M/s Ambey Traders . 9. The, first and foremost, contention raised by Mr. Jain, ld. Counsel is that, multiple suppliers being common in the impugned orders, a common adjudication order should have been passed in this matter. The second submission is that there are different proper officers who are passing impugned orders in respect of the Petitioner. 10. In respect of the first contention, in the opinion of this Court, a perusal of the various impugned orders itself would show that it is not merely t....
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.... be the proper officer in such circumstances. 14. In any event, both these contentions raised by the Petitioner can also be raised in the appeals to be filed by the Petitioner under Section 107 of the CGST Act, 2017. 15. Considering that the adjudication of the impugned orders and the grounds raised by the Petitioner would require factual analysis of various facts in the maze of transactions, which are set out in the different impugned orders, the same would not be feasible to be carried out in writ jurisdiction. 16. However, the Court does note prima facie that there is overlapping in the transactions leading to the various impugned orders. There is also clear overlapping in the suppliers mentioned in the different impugned orders....