TaxTMI 
TaxTMI 
TaxTMI 
2025 (8) TMI 1389
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....ders-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 under Section 74 of the Central Goods and Service Tax Act, 2017 (hereinafter, 'the CGST Ac....
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....ation 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, 2022 is being pressed by the Petitioner. 13. In addition, the Order-in-Original dated 28th January 2025 imposes a demand of Rs. 79,542,28....
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.... 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 Meena/ 2024-25 dated 01.02.2025 2017-18, 2018-19, 2019-20, 2020-21 Tax 2,30,91,108/- (interest and penalty also demanded) Yes, in r/o 7 suppliers, namely * M/s KM Enterprises * Radhey Enterprises(07EBPPK8485K1ZO), * Fusion Impex * Balaji Enterprises, * Ambey Traders * Radhey Ent....
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....ifferent 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 the Petitioner who has been investigated or against whom the demands have been raised. There are several other persons who are involved in these matters, who have either been suppliers of the goods or the availers of the Input Tax Credit (hereinafter, ITC). 11. Under such circumstances, it cannot be presumed that a single order can be passed, only keeping the Petitioner in mind. All these impugned orders raise different issues relating to different parties and the availment of ITC, which has been passed o....
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....ma 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. 17. In view of the above, the Petitioner is permitted to file 6 individual appeals against the impugned orders. However, with respect to pre-deposits, this Court is of the opinion that the same shall be made only in respect of the order dated 28th January, 2025, where the demand is to the tune of Rs. 15,90,84,564/-, including the penalty. The tax demanded is Rs. 7,95,42,282/-. 18. Mr. Jain, ld. Counsel, submits that a sum of Rs. 35,00,000/- has already been deposited by the Petitioner under protest. The pre-deposit shall be made in respect of this order ....