TaxTMI 
TaxTMI 
2025 (11) TMI 931
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.... 17th December,2023 (hereinafter, 'impugned SCN') and the impugned assessment order dated 27th April, 2024 pertaining to the financial year 2018-19. Vide the impugned order, total demand of Rs 7,97,290/- has been confirmed against the Petitioner, out of which Rs. 391,976/- and Rs. 3,66,166/- is the interest amount. 3. The petition also raises a challenge to the order dated 11th September, 2025, wherein the Petitioner's bank account bearing No. 352701010111624, Union Bank of India, Jain Bhawan, Delhi Cantt, had been provisionally attached under Section 83 of Central Goods and Services Tax Act,2017 (hereinafter, 'CGST Act'). 4. In addition, the present petition also challenges the vires of the following notifications....
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....ation No. 56 of 2023 (State Tax) is concerned, the challenge is to the effect that the same was issued on 11th July, 2024 after the expiry of the limitation in terms of the Notification No. 13 of 2022 (State Tax). 5. In fact, Notification Nos. 09 and 56 of 2023 (Central Tax) were challenged before various other High Courts. The Allahabad Court has upheld the validity of Notification no.9. The Patna High Court has upheld the validity of Notification no. 56. Whereas, the Guwahati High Court has quashed Notification No. 56 of 2023 (Central Tax). 6. The Telangana High Court while not delving into the vires of the assailed notifications, made certain observations in respect of invalidity of Notification No. 56 of 2023 (Central ....
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....country. 8. Issue notice on the SLP as also on the prayer for interim relief, returnable on 7-3- 2025." 7. In the meantime, the challenges were also pending before the Bombay High Court and the Punjab and Haryana High Court. In the Punjab and Haryana High Court vide order dated 12th March, 2025, all the writ petitions have been disposed of in terms of the interim orders passed therein. The operative portion of the said order reads as under: "65. Almost all the issues, which have been raised before us in these present connected cases and have been noticed hereinabove, are the subject matter of the Hon'ble Supreme Court in the aforesaid SLP. 66. Keeping in view the judicial discipline, we refrain from g....
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...., there are six categories of cases which are pending before this Court. While the issue concerning the validity of the impugned notifications is presently under consideration before the Supreme Court, this Court is of the prima facie view that, depending upon the categories of petitions, orders can be passed affording an opportunity to the Petitioners to place their stand before the adjudicating authority. In some cases, proceedings including appellate remedies may be permitted to be pursued by the Petitioners, without delving into the question of the validity of the said notifications at this stage. 11. The said categories and proposed reliefs have been broadly put to the parties today. They may seek instructions and revert by to....
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....gned order was passed more than 18 months ago. However, no challenge has been raised by the Petitioner against the impugned order, though the same is an appealable order. Furthermore, the order directing provisional attachment is dated I1th September, 2025, and it is only thereafter that the Petitioner has chosen to file the present petition. 8. Let the statement of Petitioner's bank account, which was attached, be placed before the Court on the next date of hearing. 9. Let the Id. Panel Counsel for the Respondent seek instructions as to whether any amount has been debited from the credit ledger of the Petitioner or not." 10. In the opinion of this Court, since the Petitioner has already voluntarily deposited a sum ....